Love & Lust is a service provided by Sirob OÜ (hereinafter also referred to as “Sirob” or “Provider”), acting as Controller in accordance with relevant data protection provisions. Please find the full company and contact details below:
The protection of personal data has the highest priority for us. We would therefore like to inform you about which data we collect when, and how we process your personal data. This privacy notice describes the collection and processing of personal data on the website https://www.loveandlustgame.com (hereinafter referred to as "Website") and our mobile app (“App”). To the extent this privacy notice doesn’t explicitly discriminate, it applies both to the Website and the App (together “Service”).
In principle, we only process personal data of users as necessary to provide a functional Service, our contents and to provide our services.
We mostly process personal data according to one of the following legal bases:
Whenever we collect the data subject’s consent to the processing of personal data, Art. 6 para. 1 a EU General Data Protection Regulation (GDPR) serves as the legal basis.
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
If the processing of personal data is necessary for compliance with a legal obligation which the Controller is subject to, Art. 6 para. 1 c GDPR serves as the legal basis.
If processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party and if such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 f GDPR serves as the legal basis.
In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent.
Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.
Unless otherwise stated, all data processing operations take place within the EU or the EEA countries.
Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations.
A transfer of personal data outside the EU or the EEA shall only take place on the basis of an adequacy decision of the European Commission or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. A list of current adequacy decisions (as well as information about the effect of the ECJ’s ruling in the case C-311/18 on Privacy Shield) is available on the European Commission's website.
Regardless of whether you take advantage of any of the Website’s features we automatically collect data about your use of the Website. This includes in particular the accessed URL, access date and time, transferred data volume, http status code of the access reply, web browser type and operating system, HTTP referrer, as well as IP address. This information is not associated with your person.
We collect and process such data to ensure Website operation and availability. In addition, it is used to analyse, store and evaluate information about user behaviour anonymously and to continuously improve and further develop our service. We only store your IP address in the log files for a limited period of time, if this is necessary for security purposes.
These purposes constitute our legitimate interest, which justifies data processing pursuant to art. 6 par. 1 lit. f) GDPR.
For the avoidance of doubt, please note that we do not collect any personal data when you download, install or run our App without logging into your account (see below).
When creating a User account, we collect and store the following data: email, player name or alias, gender, browser or device language, country (via IP address). We need this information in order to assign your account uniquely to yourself and make sure no duplicate accounts are created. The provision of all mentioned data is required to perform the contract you enter into with us regarding the use of our services. Failure to provide it will result in unavailability of our services. Further data may be added on a voluntary basis, such as profile pictures, age, relationship status.
Account creation is currently only supported via Apple or Google, i.e. you can only sign in through your pre-existent Apple account or Google account. We may pull your email address from the relevant Apple or Google account once you register, although in some cases we will only receive a private relay email address (not your actual email address) from those providers. A stand-alone registration is not supported.
The legal basis for processing is therefore art. 6 par. 1 lit. b) GDPR.
We adopt appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of personal data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.
In addition to the data controller, in some cases, other parties involved in the organization of Love & Lust (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as data processors by the data controller. The updated list of processors can always be requested from the data controller.
The data is processed at the data controller's operational offices and in any other place where the parties involved in the processing are located. Personal Data may be transferred to a country other than the one in which the data subject is located.
We use the information we collect in various ways, including to: - Provide, operate, and maintain our Service - Improve, personalize, and expand our Service - Understand and analyse how you use our Service - Develop new products, services, features, and functionality - Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes - Send you emails - Find and prevent fraud
In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf (“Processors”). This applies for instance to hosting providers. None of these actors shall process your data for their own purposes. As far as legally required, we have entered into agreements pursuant to art. 28 GDPR with Processors processing your personal data on our behalf.
Please note that, in addition to what specified in this privacy notice, your data may be processed in compliance with legal obligations which we are subject to. For instance, we may be obliged to store your data for a legally determined period to comply with tax law provisions. Please contact us in case you want to learn further details about such processing activities.
In such cases the legal basis of the processing is art. 6 par. 1 lit. c) GDPR.
In order to improve user experience of our Website and to enable selected functions, we implement cookies or other tracking technologies (hereinafter jointly referred to as “Cookies”) on various pages. These are small data sets being stored on your device. Some of the Cookies we use expire after the end of the browser session, i.e. after closing your browser (so-called session Cookies). Other Cookies remain on your device and enable us or our partner companies to recognize your browser or device on your next visit (persistent Cookies).
You can set your browser preferences in order to be notified about the setting of Cookies and decide individually about accepting or refusing them in certain cases or generally. You can also manually delete Cookies from your device at any time.
Failure to accept Cookies may result in minor limitations in our service’s functionalities.
Cookies are stored on the user's computer and from there transmitted to our site. Therefore, you as a user have full control over the use of Cookies. You can deactivate or restrict the transmission of Cookies by adjusting the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If Cookies are deactivated for our Website, it may no longer be possible to use all functions of the Website in full. You can also manage your cookie preferences via recognized third-party services such as http://www.youronlinechoices.eu/ (if you’re based in the EU).
Some of the Cookies we use are strictly necessary to allow us to deliver the service you requested or to operate our Website. Some elements of our Website require that your browser be identified after page changes. Such technical Cookies may collect personal information about you, such as IP address, log-in information, etc.
The processing of personal data through strictly necessary cookies – if any – is art. 6 par. 1 lit. f) GDPR. In case such cookies are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1 lit. b) GDPR.
In addition, we use third-party Cookies to monitor and evaluate user behaviour for statistics and market analysis purposes. Such Cookies are provided by third parties and implemented in our Website. Please refer to the following sections for details. Such Cookies allow us to analyse your use of our service and improve it continuously. Analytics allow us to offer you a better service that meets your interests better.
Unless otherwise specified, the legal basis of processing through other Cookies mentioned below is your consent pursuant to art. 6 par. 1 lit. a) GDPR. Unless otherwise specified, the lifetime of Cookies used based on your consent expires upon withdrawal of your consent.
GOOGLE ANALYTICS
We implement "Google Analytics". Google Analytics is a web analysis service provided by Google Inc. The information generated by the Google Analytics Cookie about your use of our Website is generally transmitted to and stored by Google on servers in the United States. IP anonymization has been activated on our Website: this means that the IP address of users based within the European Union or the European Economic Area is abridged, and therefore anonymized, before being transferred abroad. Only in exceptional cases is the unabridged IP address transferred to a Google servers in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, to draft reports about Website activity and to provide us with other services relating to Website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not put in relation with other Google data. You may object to the use of Cookies by selecting the appropriate settings on your browser, however please note that doing so may result in limited functionality of this Website. You can also prevent Google from collecting the data generated by the Cookie and relating to your use of the Website (including your IP address) and processing this data by installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
GOOGLE ANALYTICS FOR FIREBASE
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited. To find out more about Google's use of data, consult Google's partner policy (https://www.google.com/policies/privacy/partners/). Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. On our App we use Identifiers to run the Firebase Analytics service. You may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data processed: Identifiers (Google Advertiser ID or IDFA, for example); Usage Data.
GOOGLE ADS AND CONVERSION MEASUREMENT
We use the online marketing method Google Ads to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. This allows us to display ads for and within our online offering in a more targeted manner, so that users are only presented with ads that are potentially relevant to their interests. If, for example, a user is shown ads for products that they have shown interest in on other online offerings, this is referred to as ‘remarketing’. For these purposes, when you visit our website and other websites on which the Google advertising network is active, Google immediately executes a code from Google and so-called (re)marketing tags (invisible graphics or code, also known as ‘web beacons’) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies may also be used instead of cookies). This file records which websites the user has visited, which content they are interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit time and other information about the use of the online offer.
We also receive an individual ‘conversion cookie’. Google uses the information collected with the help of the cookie to compile conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that can be used to personally identify users. User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process the name or email address of users, for example, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. This means that, from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about users is transmitted to Google and stored on Google's servers in the United States.
GOOGLE TAG MANAGER
Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not create user profiles, store cookies or perform independent analyses. It is used solely to manage and display the tools integrated via it. However, Google Tag Manager does collect your IP address, which may also be transferred to Google's parent company in the United States.
In relation to all of the above-mentioned services, to find out further information about how Google handles personal data, please refer to Google's privacy policy: https://policies.google.com/privacy?hl=en
MAMOTO
Our service uses Matomo, a web analytics service, to help us analyze and improve the use of our service. Matomo uses cookies to collect information about your use of our service (such as pages viewed, time spent, and interactions). This information is stored on our own servers and is not shared with any third parties, IP addresses are anonymized before being stored so that they cannot be directly linked to a specific individual.
You can prevent the storage of Matomo cookies by adjusting your browser settings accordingly; however, please note that this may limit the use of certain features on our service.
For further information about Matomo’s privacy practices, please visit: https://matomo.org/privacy-policy/
Under the CCPA, among other rights, California consumers have the right to:
As a data subject, you have the following rights pursuant to the GDPR:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to notification - If you have exercised your right to have the Controller rectify, erase or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section.
Your right to withdraw consent - You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please reach out for us at the contact details indicated on the Website if you wish to make a request.
Your right to file a complaint - You can also complain to a data protection authority if you do not agree on how we have used your data.
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Love & Lust does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
The Love & Lust App is intended for adults. You must be at least 18 years old, or the legal age of majority in your country of residence (whichever is higher), to use our App.
Due to the dynamic development of the Internet, new technologies and possibilities are constantly developing. To enable us to offer you these possibilities and technologies, we reserve the right to change this privacy notice for the future when introducing new, additional or when changing or extending existing services or service elements. The new privacy notice shall apply from the date of its update on the Service.