PRIVACY POLICY OF CLOUD GAMING BY NETLIFE

The CLOUD GAMING BY NETLIFE platform is owned and operated by AWG BH Ecuador SA, with registered address at Nuñez de Vela E3-13, Edif. Torre del Puente Quito; Pichincha. You can contact our Data Protection Officer via email at: datospersonales@netlife.net.ec.

1. Introduction

At CLOUD GAMING BY NETLIFE, we aim to provide you with the best possible experience to ensure you enjoy our service today, tomorrow, and in the future. To achieve this, we need to understand your gaming habits so we can offer you exceptional and personalized service.

That said, the privacy and security of your personal data are of great importance to us. Therefore, we want to clearly explain how and why we collect, store, share, and use your data, and show you the controls and options available for you to choose when and how to share your data.

That's our goal, and we'll explain it in more detail in this Privacy Policy ("Policy").

2. About this Policy

This Policy provides essential information regarding the use that Netlife Ecuador (owner of the CLOUD GAMING BY NETLIFE platform, hereinafter "CLOUD GAMING BY NETLIFE") makes of your data. The Policy applies to all CLOUD GAMING BY NETLIFE services and associated services (hereinafter, "CLOUD GAMING BY NETLIFE"). The terms governing the use of the CLOUD GAMING BY NETLIFE Service are defined in our Terms of Use and EULA..

Periodically, we may develop new services or offer additional services. If the introduction of these new or additional services results in any changes to how we collect or process your data, we will provide you with additional information and conditions or policies. Unless otherwise stated, when these new or additional services are introduced, they will be subject to this Policy.

The main purpose of this Policy is to:

Ensure you understand what personal data we collect about you, why we do it, and with whom we share it;
Explain how we use the personal data you share with us to control, manage, and ensure the functionality of the CLOUD GAMING BY NETLIFE Service when you use it; and
Explain your rights and options regarding the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you understand our commitment to your privacy.

If you have any questions or comments regarding the processing of your data, you can email datospersonales@netlife.net.ec. If you do not agree with the content of this Policy, please remember that you decide whether you want to use the CLOUD GAMING BY NETLIFE Service.

3. Your Rights and Preferences: Options and Control

As you may already know, the Organic Law on Personal Data Protection (“LOPDP”) grants individuals certain rights related to their data. The rights granted to individuals are:

Right of access: the right to be informed and request access to the personal data we process;
Right of rectification: the right to request that we correct or update your data when it is inaccurate or incomplete;
Right to erasure: the right to request that your data be deleted;
Right to restriction of processing: the right to request that the processing of all or some of your data be temporarily or permanently stopped;
Right of objection:
- the right, at any time, to object to the processing of your data for reasons related to your particular situation;
- the right to object to the processing of your data for direct marketing purposes;
Right to data portability: the right to request a copy of your data in electronic format and the right to transmit such data for use in a third-party service;
Right not to be subject to automated individual decision-making: the right not to be subject to decisions based solely on automated decisions, including profiling, when the decision may have a legal effect on you or produce a similarly significant effect.
The right to revoke consent is granted through the Privacy Settings panel at any time.

To enable you to easily exercise these rights and record your preferences regarding how CLOUD GAMING BY NETLIFE uses your data, we will provide you with access to the following settings through the Account Settings page:

Privacy Settings: allows you to control some of the categories of personal data we process and allows you to access your data, change your avatar, as well as consent to or revoke your consent regarding commercial communications you may receive from CLOUD GAMING BY NETLIFE.

You can contact Megadatos S.A, S.L CLOUD GAMING BY NETLIFE at Nuñez de Vela E3-13, Edif. Torre del Puente Quito; Pichincha; or you can contact us via datospersonales@netlife.net.ec, by submitting the request posted on our website: netlife.ec, Ref: Data Protection, to exercise your rights. You must indicate the rights you wish to exercise and prove your identity as a requester when necessary. Likewise, we inform you that you have the right to file a complaint if you believe that there has been any kind of infringement about the processing of your data.

4. How do we collect your data?

We collect your data in the following ways:

Registering for the CLOUD GAMING BY NETLIFE service: When you register to create an account on the CLOUD GAMING BY NETLIFE Service, we collect certain personal data so you can use the CLOUD GAMING BY NETLIFE Service, such as an email address, later, a username (alias) and an approximate date of birth (i.e., month and year). In those plans that require payment for their use, we also collect data related to the payment method, and therefore, the payment platform used by the CLOUD GAMING BY NETLIFE Service ensures its proper protection.
Using the CLOUD GAMING BY NETLIFE Service: When you use the CLOUD GAMING BY NETLIFE Service, we collect personal data about the use of the CLOUD GAMING BY NETLIFE Service, such as which games you have played, when you have played them, and how long you have been playing each one, as well as which games have been selected as favorites from the CLOUD GAMING BY NETLIFE Service catalog. Each game has a minimum age rating that the user must have to access and play the game. This rating is determined by the official rating, known as the Pan European Game Information ("PEGI"), which establishes the appropriate minimum age to play video games based on their category. PEGI aims to guide consumers about the suitability of playing a specific game up to the minimum age recommended by PEGI. Therefore, when collecting data about the games the user plays, we may also collect PEGI data.
Collecting personal data that allows us to provide you with additional features/functionality: from time to time, we also offer you the opportunity to provide us with additional personal data or give us your permission to collect it; for example, to provide you with more features or functionalities.

We use anonymous and additional information for purposes including testing our computer systems, research, data analysis, marketing, and promotion models, improving the CLOUD GAMING BY NETLIFE Service, and developing new features and functionalities within the CLOUD GAMING BY NETLIFE Service. However, since the data is anonymized, it is disconnected from the data subject, preventing their identification.

5. How and what personal data do we collect from you?

We have outlined in the tables below the categories of personal data we collect and use about you:

Personal data collected when registering for the CLOUD GAMING BY NETLIFE Service

Categories of Personal Data	Description of Category
Check-in Data	Consists of the personal data you provide or we collect to allow you to register and use the CLOUD GAMING BY NETLIFE Service. This includes your username for the CLOUD GAMING BY NETLIFE Service, approximate date of birth (i.e., month and year), and your email address. Additionally, to record the user's acceptance of the privacy policy and Terms and Conditions of the CLOUD GAMING BY NETLIFE Service, we record the email and the exact timestamp when the user accepted it. The personal data we request is necessary to create your account. However, you have the option to provide us with additional personal data to further customize your account, such as an image or avatar. The exact personal data we collect may vary depending on the type of CLOUD GAMING BY NETLIFE service plan you have subscribed to.

Categories of Personal Data

Description of Category

Check-in Data

Consists of the personal data you provide or we collect to allow you to register and use the CLOUD GAMING BY NETLIFE Service. This includes your username for the CLOUD GAMING BY NETLIFE Service, approximate date of birth (i.e., month and year), and your email address.

Additionally, to record the user's acceptance of the privacy policy and Terms and Conditions of the CLOUD GAMING BY NETLIFE Service, we record the email and the exact timestamp when the user accepted it.

The personal data we request is necessary to create your account. However, you have the option to provide us with additional personal data to further customize your account, such as an image or avatar. The exact personal data we collect may vary depending on the type of CLOUD GAMING BY NETLIFE service plan you have subscribed to.

Personal data collected through your use of the CLOUD GAMING BY NETLIFE Service

Categories of Personal Data	Description of Category
CLOUD GAMING BY NETLIFE Service Usage Data	These are the personal data collected when you use the CLOUD GAMING BY NETLIFE Service and may include: · Information about your type of CLOUD GAMING BY NETLIFE Service plan. · Information about your interactions with the CLOUD GAMING BY NETLIFE Service, including the date and time of any requests you make and the games you have played and selected as favorites. · Messages you send and/or receive through CLOUD GAMING BY NETLIFE and your interactions with the CLOUD GAMING BY NETLIFE Customer Service team. · Technical data that may include URL information, cookie data, your IP address, unique device ID (to prevent unwanted use of the service), and the types of devices you use to access or connect to the CLOUD GAMING BY NETLIFE Service, device attributes, device and network performance, browser type (if accessed from a web browser), preferred language, Firebase Device Registration Token (used for sending messages to the app), country from which you are connecting, information enabling digital rights management, operating system, and version of the CLOUD GAMING BY NETLIFE app. You can find more information about the technical data we process when accessed from a web browser in our Cookie Policy.
Age	· During the registration process, the user's age is requested to determine if they are a child and to activate the parental acceptance process and propose to the user the games within the reported age range with the recommendations of each video game based on its corresponding PEGI, which is a European system for classifying the content of video games and other types of entertainment software based on the age of the users.

Categories of Personal Data

Description of Category

CLOUD GAMING BY NETLIFE Service Usage Data

These are the personal data collected when you use the CLOUD GAMING BY NETLIFE Service and may include:

· Information about your type of CLOUD GAMING BY NETLIFE Service plan.

· Information about your interactions with the CLOUD GAMING BY NETLIFE Service, including the date and time of any requests you make and the games you have played and selected as favorites.

· Messages you send and/or receive through CLOUD GAMING BY NETLIFE and your interactions with the CLOUD GAMING BY NETLIFE Customer Service team.

· Technical data that may include URL information, cookie data, your IP address, unique device ID (to prevent unwanted use of the service), and the types of devices you use to access or connect to the CLOUD GAMING BY NETLIFE Service, device attributes, device and network performance, browser type (if accessed from a web browser), preferred language, Firebase Device Registration Token (used for sending messages to the app), country from which you are connecting, information enabling digital rights management, operating system, and version of the CLOUD GAMING BY NETLIFE app. You can find more information about the technical data we process when accessed from a web browser in our Cookie Policy.

Age

· During the registration process, the user's age is requested to determine if they are a child and to activate the parental acceptance process and propose to the user the games within the reported age range with the recommendations of each video game based on its corresponding PEGI, which is a European system for classifying the content of video games and other types of entertainment software based on the age of the users.

Personal data collected with your consent to allow us to provide you with additional features or functionalities.

Categories of Personal Data	Description of Category
Location Data	Please note that we do NOT access your GPS or Bluetooth to obtain the exact location of your mobile device. We use Google APIs to identify the country from which the device is connected to validate the correct access and use of the CLOUD GAMING BY NETLIFE service. For example, the country or city where you are located, to comply with our license agreements, offer features, information, advertising, or any other content based on your location and use of the service. Additionally, we use your IP address to facilitate analysis to resolve issues and validate the correct use of the service.
Contests, Sweepstakes, and Survey Data	These personal data are used to allow you to register and participate in such promotions. The exact personal data collected will vary depending on the promotion. Such personal information is used to enable CLOUD GAMING BY NETLIFE to send you marketing communications via email and automatic notifications.
Marketing Data	This personal information is used to enable CLOUD GAMING BY NETLIFE to offer games and other initiatives through app alerts.
Google Play Transaction	We collect information related to purchase history, which includes: purchased subscription, purchase sources (Play Store or other future sources), Play Store purchase token: used to uniquely identify a purchase in the store, Play Store order ID, Play Store country, price paid, and currency. Payment status: To determine whether the purchase has been paid or not before running a game. Subscription status. Promotion code: Determines if the user benefited from a promotion. Cancellation reason and user feedback. Subscription start and expiration time.

6. What purposes do we use your data for?

When you use or interact with the CLOUD GAMING BY NETLIFE Service, we use different technologies to process your data for various reasons. The following table shows the purposes of processing your data, the associated legal bases that allow us to process your data, and the categories of personal data (identified in section 5 "How and what personal data do we collect from you?"). Used for the following purposes:

Description of why CLOUD GAMING BY NETLIFE processes your data ("purpose of processing")	Legal basis for processing	Categories of personal data used by CLOUD GAMING BY NETLIFE for processing
Providing and customizing the functionality of the CLOUD GAMING BY NETLIFE Service according to the user.	· Contract performance · Consent	· Account registration data · Service usage data · PEGI game acceptance data
Understanding the use of the CLOUD GAMING BY NETLIFE Service to improve service functionality, develop new products and services provided by CLOUD GAMING BY NETLIFE, and analyze its usage.	· Consent and acceptance of this Privacy Policy, Cookie Policy and Terms of Use and EULA of the CLOUD GAMING BY NETLIFE Service.	· Service usage data
Offering the user features, information, recommendations, advertising, or any other content based on their service usage, including their location.	· Consent	· Service usage data · Location data
Understanding service usage to ensure the technical functionality of the CLOUD GAMING BY NETLIFE Service.	· Contract performance · Legitimate interests	· Account registration data · Service usage data · PEGI game acceptance data
Communicating with you for purposes related to the CLOUD GAMING BY NETLIFE Service.	· Contract performance	· Account registration data · Service usage data
Validating your payment to prevent or detect fraud, including fraudulent payments and fraudulent use of CLOUD GAMING BY NETLIFE, and managing billing services.	· Contract performance · To comply with legal obligations	· Payment data
Communicating with you regarding your participation in surveys, contests, sweepstakes, and promotions.	· Consent	· Contests, sweepstakes, and survey data · Marketing data

7. Sharing of your data

This section outlines the different categories of recipients of the personal data collected or generated through your use of the CLOUD GAMING BY NETLIFE Service.

Publicly available information

The following personal data will always be publicly available on the CLOUD GAMING BY NETLIFE Service: Avatar and username, which will be shared with other users of CLOUD GAMING BY NETLIFE using the service.

Information we may share

Recipient Category	Purpose of Sharing
Service Providers and Other Collaborators	We use technical service providers who provide the technical infrastructure needed to deliver the CLOUD GAMING BY NETLIFE Service, particularly providers who host, store, manage, and maintain the CLOUD GAMING BY NETLIFE application, its content, and the data we process. We use technical service providers to assist us in communicating with you, as described in Section 6 of this Policy, among other things, for the resolution of technical incidents that may result in an exchange of questions-answers-technical data that we may need to resolve the incident. We use marketing and advertising partners to display more personalized content or to help us understand your use of the CLOUD GAMING BY NETLIFE Service and provide you with a better service. We may also share personal data with some marketing or advertising partners or providers to send you promotional communications about CLOUD GAMING BY NETLIFE. · We may also share your data in a pseudonymized format with our industry partners to help them understand how activities and games work on CLOUD GAMING BY NETLIFE. · Similarly, we share your data in a pseudonymized format with marketing partners who assist us with promotional activities and with advertisers who enable us to offer a free service.
Academic Researchers	We will share your data for activities such as statistical analysis and academic studies, but only in a pseudonymized format.
Other Business Entities	We will share your data with other companies with whom we have marketing agreements to conduct our day-to-day business operations and to enable us to maintain and provide the CLOUD GAMING BY NETLIFE Service.
Law Compliance and Data Protection Authorities	We will share your data to comply with a legal obligation under applicable law or to respond to a valid legal process, such as a search warrant, court order, or subpoena. We may also share your data when we believe in good faith that it is necessary for our interest or the legitimate interest of third parties related to national security, law enforcement, lawsuits, criminal investigation, protection of the safety of any person, or to prevent imminent death or bodily harm, provided that we believe that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your data.

8. Data Retention and Deletion

We retain your data only for as long as necessary to provide the CLOUD GAMING BY NETLIFE Service and for legitimate and essential business purposes, such as maintaining the performance of the CLOUD GAMING BY NETLIFE Service, making data-driven business decisions about new features and offers, complying with our legal obligations, and resolving disputes. We retain some of your data for as long as you are a user of the CLOUD GAMING BY NETLIFE Service.

Upon request, we may delete or anonymize your data so that you are not identified, unless we can or are legally required to retain certain personal data, including the following cases:

If there is an unresolved issue related to your account, such as outstanding payments on your account or an unresolved claim or dispute, we will retain the necessary personal data until such issue is resolved;
When we are required to retain personal data to comply with our legal, tax, accounting, and auditing obligations, we will retain the necessary personal data for the period required by applicable law; and/or
When necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

9. Links

We may display third-party advertisements and other content linked to third-party websites. We cannot control or be responsible for the privacy practices and content of third parties. If you click on an advertisement or link from a third party, you understand that you are leaving the CLOUD GAMING BY NETLIFE Service and that any personal information you provide will not be covered by this Policy. Please read the privacy policies of the third parties responsible for the website you are accessing to understand how they collect and process your data.

10. Protection of Your Data

We are committed to protecting the personal data of our users. We implement appropriate technical and organizational measures to help protect the security of your data. However, please note that no system is completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to protect against unauthorized access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we recommend that you use a unique and strong password to limit access to your computer and browser and log out after using the CLOUD GAMING BY NETLIFE Service.

11. Conditions Applicable to Child Consent Regarding CLOUD GAMING BY NETLIFE Services

Following the GDPR, the processing of a child's data is lawful when the child is at least 16 years old. If the child is under 16 years old, such processing will only be considered lawful if and only to the extent that consent was given or authorized by the holder of parental responsibility or guardianship over the child. Member States may establish by law a lower age for these purposes, provided it is not lower than thirteen years. In the case of Spain, it is set at 14 years. CLOUD GAMING BY NETLIFE will make reasonable efforts to verify that consent was given or authorized by the holder of parental responsibility or guardianship over the child, taking into account the available technology. If you have any questions or comments regarding the parental control process of CLOUD GAMING BY NETLIFE or want to inform us about any aspect related to a child, you can do so by email (using the email datospersonales@netlife.net.ec). CLOUD GAMING BY NETLIFE will act with total confidentiality in the analysis of the information provided.

12. Avatar or Profile Picture

Please note that if you add your image as a profile photo, it will be public, and anyone or any user will be able to access and view it. To configure the Privacy of the profile picture you have chosen, you must access the Profile Settings.

13. Changes to this Privacy Policy

Occasionally, we may make changes to this Policy. If we make significant changes, we will provide you with prominent notice as circumstances warrant, for example, by displaying one on the CLOUD GAMING BY NETLIFE Service or sending you an email. We may provide advance notice.

Therefore, please be sure to carefully read any notifications.

14. How to Contact Us

If you have any questions about this Policy, please contact our Data Protection Officer by email at: datospersonales@netlife.net.ec or by writing to the following address:

[Megadatos S.A], CLOUD GAMING BY NETLIFE
Nuñez de Vela E3-13, Edif. Torre del Puente
Quito; Pichincha;
The Data Controller is Megadatos S.A, owner of the CLOUD GAMING BY NETLIFE Platform.