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APP PRIVACY POLICY

  1. IDENTIFICATION AND CONTACT INFORMATION

  1. INFORMATION

This Privacy Policy applies to the processing of the personal data of users (hereinafter, the “User(s)”) who use any of BLUETILE’s mobile applications (hereinafter, the “Apps”), as well as any other data that the User may provide in the future on the Apps. These personal data will be processed by BLUETILE as the data controller for the purposes indicated in this Privacy Policy.

Users should carefully read this Privacy Policy, which has been drafted in a clear and simple manner.

  1. OBLIGATION TO PROVIDE DATA

The data requested in the Apps are, in general, mandatory in order to comply with the purposes for which they are being collected, unless otherwise specified in the required field.

Therefore, if the User does not provide BLUETILE with these data or does not provide them correctly, the User’s requests may not be attended.

  1. ORIGIN OF THE DATA

The data processed by BLUETILE for the purposes listed in the following section are obtained from the User, either directly or from the User’s use of the App.

  1. FOR WHAT PURPOSES WILL BLUETILE PROCESS PERSONAL DATA? WHAT USER DATA WILL BLUETILE PROCESS? WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF USER DATA BY BLUETILE?

Your personal data will be processed in accordance with the applicable regulations on the protection of personal data, including Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation”) and Basic Law 3/2018 on the protection of personal data and guarantee of digital rights (“LOPDGDD”).

We will process your personal data for the following purposes and legal bases:

Purpose

Categories of personal data

Legal basis

Retention period

Management of the contractual relationship with the User: The provision of the services and functionalities offered by the relevant App to the User when playing a game or interacting with the App.

  • Identifying data: IP address and IDFA, Apple, Amazon or Google User ID, name associated with the device.
  • Technical device data.
  • Other data: cookies and similar identifiers.

Article 6.1.b) of the General Data Protection Regulation.

Managing, controlling and executing the legal relationship.

5 years (Article 1964.2 of the Civil Code)

Answer the queries raised by the User through the contact channels provided: to manage, process and provide support for the requests, applications, incidents, complaints, or queries made by the User through the different communication channels made available in the Apps.

  • Identification data: IP address and IDFA, Apple, Amazon or Google User ID, name and surname.
  • Contact details: e-mail address.
  • Other data: any data that may be provided by the User in relation to the relevant query or request.

Article 6.1.b) of the General Data Protection Regulation.

Managing, controlling and executing the legal relationship.

3 years (Article 72 of the LOPDGDD)

Preparation of reports, statistics, and internal analysis to improve the Apps: to analyze, manage and prepare internal reports and statistics on User behavior in order to implement improvements to the Apps, using aggregated information.

  • Identifying data: IP address and IDFA, Apple, Amazon or Google User ID, name associated with the device.
  • Aggregated User Information.
  • Technical device data.
  • Other data: The Google Advertising ID is a unique, non-personalized, and non-permanent ID for advertising for a device using Android. Also, Apple ID information may be processed for the referred purposes.

Article 6.1.f) of the General Data Protection Regulation.

Legitimate interest of BLUETILE in analysing the use and operation of the Apps to improve them.

3 years (Article 72 of the LOPDGDD)

Optimization of services and detection of errors and problems: to improve and optimize our services, as well as to detect App errors and technical problems.

  • Identifying data: IP address and IDFA, Apple, Amazon or Google User ID, name associate to the device.
  • Contact details: e-mail.
  • Data obtained through User-generated content: comments and ratings.

Article 6.1.f) of the General Data Protection Regulation.

Legitimate interest of BLUETILE in analysing the use and operation of the App to determine potential upgrades.

3 years (Article 72 of the LOPDGDD)

Personalization of advertisements shown in the App: This will be done based on your Google Advertising ID, Amazon ID or Apple ID.

  • Identifying data: IP address and IDFA, Apple, Amazon or Google User ID, name associate to the device.
  • Other data: Google Advertising ID and the data collected through this ID, including the advertising content you have viewed and your interactions with this content.

Article 6.1.a) of the General Data Protection Regulation.

Consent of the User.

3 years (Article 72 of the LOPDGDD)

To comply with legally established obligations: when the processing is necessary to comply with a legal obligation derived from regulations which may be applicable to BLUETILE.

Any data processed by BLUETILE that may be required for this purpose.

Article 6.1.c) of the General Data Protection Regulation.

Compliance with BLUETILE’S legal obligations: (i) detection and prevention of crimes (including fraud prevention); and (ii) compliance with applicable legislation (e.g., complying with data protection laws).

6 years (Article 30.1 of the Commercial Code)

  1. THIRD PARTY DATA

If the User provides data of third parties, the User declares that it has their consent and/or sufficient legitimacy and undertakes to provide them with the information contained in the Privacy Policy, exempting BLUETILE from any liability in this regard. However, BLUETILE may carry out the appropriate verifications to check this, adopting the corresponding due diligence measures, in accordance with data protection regulations.

  1. RECIPIENTS OF PERSONAL DATA

Personal data provided by the User through the App may be communicated to:

  1. Service providers: these are third parties that manage purchases made within the App, such as PayPal, Google Pay or Apply Pay, based on the contractual relationship with the User. Service providers can only access and use your personal data on our behalf for specific tasks, as per our instructions, and must keep the data confidential and secure. Where allowed by law, you can request a list of the service providers processing your personal data, contacting us at the address provided later
  2. Public Administrations, in the cases provided by law, based on compliance with a legal obligation.
  3. Courts and tribunals, in the cases provided for by law, based on compliance with a legal obligation.
  4. BLUETILE collaborates with third-party service providers who may have access to your personal data and will process data on behalf of BLUETILE in order to provide services related to legal, technological and IT services, in compliance with our contractual obligations and to satisfy BLUETILE’s legitimate interests (for example, to measure the effectiveness of our advertising, improve our marketing practices, and deliver more relevant ads to you and people like you). When the data processing activities requires it, we will request your explicit consent to transfer your personal data to third-party providers. Where allowed by law, you can request a list of the service providers processing your personal data, contacting us at the address provided later. You may find the list of third-party service providers in Appendix I.
  5. Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal data may be disclosed, sold, or transferred as part of such a transaction.
  6. Advertising companies which deliver advertisements on our Apps and Games may also be the recipients of your personal data. The processing of personal data by these companies is subject to their own privacy policies. You may find the list of advertising companies in Appendix II.

When BLUETILE carries out international data transfers, BLUETILE will ensure that the importer of the data is located in a country that the European Commission considers as providing an adequate level of protection. Where that is not the case, BLUETILE will (i) adopt the Standard Contractual Clauses (SCCs) of the European Commission to protect your Personal Data; and/or (ii) adopt sufficient safeguards to make sure the personal data is protected (for example, data encryption, transferring data to a third-party certified under the new EU-US Data Privacy Framework). You have the right to request a copy of the SCCs and the safeguards implemented by contacting us at the address provided later.

  1. USER RESPONSIBILITY

The User guarantees that the data provided to BLUETILE is true, accurate, complete, and up to date. To this effect, the User is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to their real situation, especially the information included by the data subject on the forms fulfilled.

Likewise, the User guarantees that it has informed the third parties of whom the User provides data, if the User does so, of the aspects contained in this document. Likewise, the User guarantees to have obtained their authorization to provide their data to BLUETILE for the aforementioned purposes.

In any case, BLUETILE is an intermediary, so the User shall be liable for any false or inaccurate information provided through the App and for any damages, direct or indirect, that this may cause to BLUETILE or third parties, as well as for any possible civil or criminal liability that may arise from the activity of users on the Apps.

  1. EXERCISE OF RIGHTS

The User may submit a request to BLUETILE, to the e-mail or postal address indicated in the heading of this Privacy Policy at any time and free of charge, in order to exercise the following rights:

  1. Right of access:

You have the right to be informed by BLUETILE of whether it is processing your personal data and, if so, to have access to such data and to receive information on the purposes for which they are processed, the categories of data affected by the processing, the recipients to whom your personal data were communicated and the foreseen period for which the data will be kept, among other information.

  1. Right of rectification and deletion:

You have the right to request the deletion of personal data provided that the legal requirements are met, and the rectification of inaccurate data concerning you when, among other reasons, such data are no longer necessary for the purposes for which they were collected.

  1. Limitation of processing:

In certain circumstances (e.g., where the user disputes the accuracy of his or her data, while the accuracy of the data is being verified), he or she may request that the processing of his or her personal data be restricted and processed only for the purpose of pursuing or defending claims.

  1. Consent withdrawal:

You also have the right to withdraw the consent at any time and free of charge, which will not impact the processing of your personal data carried out on the basis of your consent prior to the withdrawal.

  1. Objection:

You have the right to object to the processing at any time, on grounds relating to your personal situation, where the processing is based on our legitimate interest or on the legitimate interest of a third party (including processing for the purpose of direct marketing and profiling). In this case, BLUETILE will cease processing, unless legitimate reasons can be demonstrated.

  1. Portability of your data:

You will have the right to receive the personal data that you have provided to BLUETILE in a structured, common, and machine-readable format, and to be able to transmit it to another data controller without, in the cases legally provided.

  1. Automated individual decisions:

Furthermore, in addition to the above-mentioned rights, in case of automated decisions, including profiling, you have the right to obtain human intervention by BLUETILE and to express your point of view and challenge the decision.

  1. Others:

Similarly, where personal data are transferred to a third country or to an international organization, you have the right to be informed about how you can access or obtain a copy of the appropriate safeguards relating to the transfer.

In addition, you may ask questions or raise concerns about the organization's privacy policy or information processing practices. Likewise, you may lodge a complaint regarding the protection of your personal data with the competent supervisory authority, if you consider that BLUETILE has infringed the rights that are recognized by the applicable data protection regulations. The competent data protection authorities in the European Union may be found at the following link: https://ec.europa.eu/newsroom/article29/items/612080

  1. SECURITY MEASURES

BLUETILE will process the User’s data in a confidential manner and will, in accordance with the provisions of the applicable regulations, adopt appropriate technical and organizational measures to ensure the security of the data and prevent its alteration, loss, unauthorized access. The measures will be defined taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk for the rights and freedoms of natural persons.

  1. ACCESS TO YOUR INFORMATION AND YOUR CHOICES

You may access your information to update or correct it by sending an email to dpo@bluetile.com. By communicating with BLUETILE, we may send you important communications regarding the Services to which you may opt-out. Additionally, we may send you important communications regarding your request, and you will not be able to opt out of those communications.

  1. CHANGES

BLUETILE reserves the right to revise its Privacy Policy from time to time. For this reason, we ask the User to regularly check this privacy statement for the most recent version of BLUETILE’s Privacy Policy. If we make any material changes to this Privacy Policy, we’ll notify you of these changes, for example by posting them on the App or providing email or other notice, and we’ll update the “Last Updated” date at the bottom of the Privacy Policy to indicate when those changes will become effective.

APPENDIX I - LIST OF THIRD PARTY SERVICE PROVIDERS

You may find the updated list of third party service providers here.

APPENDIX II - LIST OF ADVERTISING COMPANIES

You may find the updated list of advertising companies here.

Last updated: July 2025

Barcelona, © BLUETILE GAMES, S.L. 2025. Reproduction in whole or in part is prohibited. All rights reserved.


WEBSITE PRIVACY POLICY

  1. IDENTIFICATION AND CONTACT INFORMATION

  1. INFORMATION

This Privacy Policy applies to the processing of the personal data of users (hereinafter, the “User(s)”) who browse BLUETILE’s website: https://bluetile.com/ (hereinafter, the “Website”). These personal data will be processed by BLUETILE as the data controller for the purposes indicated in this Privacy Policy.

Users should carefully read this Privacy Policy, which has been drafted in a clear and simple manner.

  1. OBLIGATION TO PROVIDE DATA

The data requested in the Website are, in general, mandatory in order to comply with the purposes for which they are being collected, unless otherwise specified in the required field. Therefore, if the User does not provide BLUETILE with these data or does not provide them correctly, the User’s requests may not be attended.

  1. BLUETILE APPS AND GAMES

BLUETILE offers access to a variety of games for Android and iOS devices. The processing of personal data within BLUETILE’s Apps and Games will be governed by its own Privacy Policy. This specific policy will be presented to the User during the installation and activation process on their device. It is the User’s responsibility to read and accept this policy before using the game.

  1. ORIGIN OF THE DATA

The data processed by BLUETILE for the purposes listed in the following section are obtained from the User, either directly or from the User’s use of the Website.

  1. FOR WHAT PURPOSES WILL BLUETILE PROCESS PERSONAL DATA? WHAT USER DATA WILL BLUETILE PROCESS? WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF USER DATA BY BLUETILE?

Your personal data will be processed in accordance with the applicable regulations on the protection of personal data, including Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation”) and Basic Law 3/2018 on the protection of personal data and guarantee of digital rights (“LOPDGGD”).

We will process your personal data for the following purposes and legal bases:

Purpose

Categories of personal data

Legal basis

Retention period

Manage participation in selection process: to manage the recruitment process and active the selection process in relation to the CV provided through the Website.

  • Identifying data: name, surname.
  • Contact details: e-mail address, postal address.
  • CV Data: professional and academic data.

Article 6.1.b) of the General Data Protection Regulation.

Managing, controlling and executing the legal relationship.

1 years (Article 59 of Royal Legislative Decree 2/2015)

Answer the queries raised by the User through the contact channels provided: to manage, process and provide support for the requests, applications, incidents, complaints, or queries made by the User through the different communication channels made available in the Website.

  • Identification data: name, surname.
  • Contact details: e-mail address.
  • Other data: any data that may be provided by the User in relation to the relevant query or request.

Article 6.1.b) of the General Data Protection Regulation.

Managing, controlling and executing the legal relationship.

3 years (Article 72 of the LOPDGDD)

  1. THIRD PARTY DATA

If the User provides data of third parties, the User declares that it has their consent and/or sufficient legitimacy and undertakes to provide them with the information contained in the Privacy Policy, exempting BLUETILE from any liability in this regard. However, BLUETILE may carry out the appropriate verifications to check this, adopting the corresponding due diligence measures, in accordance with data protection regulations.

  1. RECIPIENTS OF PERSONAL DATA

BLUETILE will transfer user data to third parties when it is necessary for the management and control of the Website and to competent authorities and bodies, courts, tribunals or any other legitimate third parties in accordance with the applicable regulations when doing so is required by these authorities.

When BLUETILE carries out international data transfers, BLUETILE will ensure that the importer of the data is located in a country that the European Commission considers as providing an adequate level of protection. Where that is not the case, BLUETILE will (i) adopt the Standard Contractual Clauses (SCCs) of the European Commission to protect your Personal Data; and/or (ii) adopt sufficient safeguards to make sure the personal data is protected (for example, data encryption, transferring data to a third-party certified under the new EU-US Data Privacy Framework). You have the right to request a copy of the SCCs and the safeguards implemented by contacting us at the address provided later.

  1. USER RESPONSIBILITY

The User guarantees that the data provided to BLUETILE is true, accurate, complete, and up to date. To this effect, the User is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to their real situation, especially the information included by the data subject on the forms fulfilled.

Likewise, the User guarantees that it has informed the third parties of whom the User provides data, if the User does so, of the aspects contained in this document. Likewise, the User guarantees to have obtained their authorization to provide their data to BLUETILE for the aforementioned purposes.

In any case, BLUETILE is an intermediary, so the User shall be liable for any false or inaccurate information provided through the Website and for any damages, direct or indirect, that this may cause to BLUETILE or third parties, as well as for any possible civil or criminal liability that may arise from the activity of users on the Website.

  1. EXERCISE OF RIGHTS

The User may submit a request to BLUETILE, to the e-mail or postal address indicated in the heading of this Privacy Policy at any time and free of charge, in order to exercise the following rights:

  1. Right of access:

You have the right to be informed by BLUETILE of whether it is processing your personal data and, if so, to have access to such data and to receive information on the purposes for which they are processed, the categories of data affected by the processing, the recipients to whom your personal data were communicated and the foreseen period for which the data will be kept, among other information.

  1. Right of rectification and deletion:

You have the right to request the deletion of personal data provided that the legal requirements are met, and the rectification of inaccurate data concerning you when, among other reasons, such data are no longer necessary for the purposes for which they were collected.

  1. Limitation of processing:

In certain circumstances (e.g., where the user disputes the accuracy of his or her data, while the accuracy of the data is being verified), he or she may request that the processing of his or her personal data be restricted and processed only for the purpose of pursuing or defending claims.

  1. Consent withdrawal:

You also have the right to withdraw the consent at any time and free of charge, which will not impact the processing of your personal data carried out on the basis of your consent prior to the withdrawal.

  1. Objection:

You have the right to object to the processing at any time, on grounds relating to your personal situation, where the processing is based on our legitimate interest or on the legitimate interest of a third party (including processing for the purpose of direct marketing and profiling). In this case, BLUETILE will cease processing, unless legitimate reasons can be demonstrated.

  1. Portability of your data:

You will have the right to receive the personal data that you have provided to BLUETILE in a structured, common, and machine-readable format, and to be able to transmit it to another data controller without, in the cases legally provided.

  1. Others:

Similarly, where personal data are transferred to a third country or to an international organization, you have the right to be informed about how you can access or obtain a copy of the appropriate safeguards relating to the transfer.

In addition, you may ask questions or raise concerns about the organization's privacy policy or information processing practices. Likewise, you may lodge a complaint regarding the protection of your personal data with the competent supervisory authority, if you consider that BLUETILE has infringed the rights that are recognized by the applicable data protection regulations. The competent data protection authorities in the European Union may be found at the following link: https://ec.europa.eu/newsroom/article29/items/612080

  1. SECURITY MEASURES

BLUETILE will process the User’s data in a confidential manner and will, in accordance with the provisions of the applicable regulations, adopt appropriate technical and organizational measures to ensure the security of the data and prevent its alteration, loss, unauthorized access. The measures will be defined taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk for the rights and freedoms of natural persons.

  1. ACCESS TO YOUR INFORMATION AND YOUR CHOICES

You may access your information to update or correct it by sending an email to dpo@bluetile.com. By communicating with BLUETILE, we may send you important communications regarding the Services to which you may opt-out. Additionally, we may send you important communications regarding your request, and you will not be able to opt out of those communications.

  1. CHANGES

BLUETILE reserves the right to revise its Privacy Policy from time to time. For this reason, we ask the User to regularly check this privacy statement for the most recent version of BLUETILE’s Privacy Policy.

Last updated: July 2025

Barcelona, © BLUETILE GAMES, S.L. 2025. Reproduction in whole or in part is prohibited. All rights reserved.