PRIVACY POLICY
INFORMATION ON THE PROCESSING OF PERSONAL DATA
We are Krakatoa, and we have developed a real world augmented reality platform, designed to allow you to interact in shared worlds, perfectly integrated with the real world. In order for you to interact in our app, we need information about you.
Protecting your privacy is very important to us. We only use your information where we have a legal basis to do so. This Privacy Policy, issued in compliance with the European regulations on the protection of personal data, will help you understand what we collect, how we use it and what choices you have when using our App. We therefore invite you to read our Terms of Service which define the contract between you and Krakatoa.
1. Data controller
The data controller is KRAKATOA SA, with a registered office in Via Luganetto 4 – 6962 Viganello – Switzerland. You can send to us any request for information concerning the processing of your personal data and exercise the rights referred to in point 5. Send your requests to the address email: contact@wallem.io
2. Categories of data processed, mode of data acquisition, purpose of the processing, legal basis and data retention time
Through the WALLEM Application, the Data Controller collects and processes the following data:
| Data | Mode of data acquisition | Purpose of the treatment | Legal basis for the treatment | Data retention time |
| We register and maintain an automatically generated internal account ID, device language, software version and platform, device model, your country and last login date. | Automatic | Use of the App and assure the most suitable experiences | Terms and conditions of the use of the app (Article 6.1.b GDPR). | We keep your data as long as the account is active or as necessary for the provision of the Service.
In case of inactivity for 24 months your account will be deleted. |
| Identification data such as:
telephone number; gender (optional and indicative only); Country in reference to n. telephone provided; IOS or Android operating system and version for statistical purposes; when necessary, we collect your e-mail address and, if you wish, you can upload a photo of yourself. |
Entered by the user during app registration ad app use | Use of the App and assure the most suitable experiences | Terms and conditions of the use of the app (Article 6.1.b GDPR).
Not providing the data could make it impossible to complete your registration as a user or the inability to access the app services. |
We keep your data as long as the account is active or as necessary for the provision of the Service.
In case of inactivity for 24 months your account will be deleted. |
| Personal Data collected in order to respond to requests sent to us via e-mail such as, for ex., those relating to maintenance activities, as well as requests relating to products and initiatives. | Provided by the user | Management of received requests | Terms and conditions of the use of the app (Article 6.1.b GDPR).
Not providing the data could make it impossible to manage your request. |
We keep your data for the time necessary to reply to the request. |
| Geolocation Data
We identify your location using GPS. The position is detected, with an update every 10 seconds, during the game and the GPS is automatically disabled at the end of the session. On the system database, the following are detected and saved, to improve the gaming experience: – the user’s last position; – the user’s position at certain times (“capture”, etc.) |
Automatic – while using our Services | Use of the App and assure the most suitable experiences | Terms and conditions of the use of the app (Article 6.1.b GDPR).
Not providing the data could make it impossible to complete your registration as a user or the inability to access the app services. |
Instant location game session, except for saved data, which is retained as long as the account is active or as necessary to provide the Service.
In case of inactivity for 24 months your account will be deleted. |
| Wallet data that we allow you to create in the app, containing your points collected through game progress and Digital Goods imported into our App. | Automatic – while using our Services | Use of the App and assure the most suitable experiences | Terms and conditions of the use of the app (Article 6.1.b GDPR).
Not providing the data could make it impossible to complete your registration as a user or the inability to access the app services. |
Instant location game session, except for saved data, which is retained as long as the account is active or as necessary to provide the Service.
In case of inactivity for 24 months your account will be deleted. |
| E-mail address | Entered by the user | Share updates and news about the Services | Consent
The consent to the processing of personal data for this purpose is optional and any refusal does not affect the use of the App. |
24 months from the last communication or until consent is revoked if previous. |
| E-mail address | Entered by the user | Sales promotions and marketing initiatives | Consent
The consent to the processing of personal data for this purpose is optional and any refusal does not affect the use of the App. |
24 months from the last communication or until consent is revoked if previous. |
| E-mail address | Entered by the user | Third party sales promotions and marketing initiatives | Consent
The consent to the processing of personal data for this purpose is optional and any refusal does not affect the use of the App. |
12 months from the issue of consent or until consent is revoked if previous. |
We require permissions to access the Personal Data on your device.
You will need to provide these permissions before the information can be processed and, afterwards, you can revoke the permission at any time. To revoke the permissions, you can use the system settings or contact the Data Controller at the contact details provided in point 1.
The revocation of one or more of these permissions may have consequences on the proper functioning of the app. In the event that you grant the permissions indicated below, the related Personal Data may be processed (accessed, modified or removed) by this app.
| Camera | Used to access the camera or capture images and videos from the device. |
| Access to the gallery | Used to access the device gallery. |
| Push notifications | Used to notify you of information relating to the game and events that may interest you. |
3. Data recipients
For the purposes indicated in this policy, your personal data may be disclosed to third parties who work in collaboration with the Data Controller in providing services.
Data may also be known by external consultants and third parties (suppliers of technical services, suppliers of instrumental services for the management / maintenance of the Application, as well as to third-party marketing companies and advertising and market research services, payment service managers, platforms for the management of virtual coins); third party services used for the functionality of the application (such as sending push notifications and SMS to create the profile) and for the management of Digital Goods.
We also have the right to provide the Data to public authorities in response to legitimate requests.
These recipients, in case that they process data on behalf of the Data Controller, will be appointed as data processors with a specific contract or other legal act.
Finally, your Data will be processed by resources (such as employees and consultants) of the Data Controller, adequately trained, who operate as personnel authorized to process personal data.
4. Transfer of data to a third country and / or an international organization
Personal data will not be transferred either to non-European third countries or to international organizations.
However, your personal data may be transferred and stored in a country outside your country of origin, for the purposes described in this Privacy Policy.
If we transfer your personal data from the EEA to other countries, we ensure that your personal data is provided with a level of protection similar to that of the EEA by ensuring that the country to which the personal data is transferred is a country that the European Commission has deemed to provide an adequate level of protection of personal data such as EEA (e.g. Switzerland).
5. Your rights (15 ss. of the GDPR)
You have the right to ask the Data Controller to access your personal data and to rectify them if they are inaccurate, to delete them or limit their processing if the conditions let it, to oppose the processing when the legal basis is constituted by the legitimate interest pursued by the Data Controller, as well as to obtain the portability of personally provided data only if subject to automated processing based on consent or contract. You also have the right to prevent the sending of commercial communications by writing to contact@wallem.io and you can request the interruption of the related service at any time, without prejudice to the lawfulness of the processing carried out up to the time of the request.
You also have the right, if you believe that the processing that concerns you violates the GDPR, to propose a complaint to a supervisory authority, in particular in the Member State in which you usually reside, work or in the place where the alleged violation has occurred pursuant to of the art. 77 of the GDPR.
6. Minors of age
Generally, our Services are not directed to minors under the age of 16 (or the age required by local law), and the Service does not knowingly collect personal data from minors.
If you are the parent or legal guardian of a minor and would like to know the personal data collected by us, or you want that information to be modified or deleted, you can contact us at contact@wallem.io
7. Information on third parties installed on the App
We use third-party services that allow them to send you advertisements according to your browsing habits.
This type of services allows the use of User’s Data for commercial communication purposes in various forms of advertising, such as banners, also in relation to the User’s interests. Some of the services may use cookies to identify the user or use the behavioral retargeting technique, i.e. display personalized advertisements based on the interests and behavior of the user, also detected outside the Wallem App. For more information on this, we suggest you check the privacy policies of the respective services.