Privacy Policy

Updated: 13/10/2021

 

PRIVACY NOTICE

We at Sulake Oy (“Sulake”, “Habbo”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you access and use our games, mobile applications, websites and related services. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you play Habbo, use our services within the Habbo mobile applications or visit our website https://www.habbo.com/ (“Service Website”), all of which together we refer to as “Services”.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the specific information below.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Sulake Oy, Dagmarinkatu 6, 00100 Helsinki, Finland is responsible (“the Data Controller”) for the processing of your Personal Data when you play Habbo, visit our Service Website or use our Services.

2. WHAT TYPES OF PERSONAL DATA DO WE PROCESS AND HOW DO WE COLLECT IT?

When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation. The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:

2.1 PERSONAL DATA PROVIDED BY YOU

When you use our Services, you provide or be asked to give us certain information, including:

  • Your account information: In order to use our Services, you need to create an account. This will also allow you to use our Services on different devices. When you create your account, we collect your log-in data (email address, password, birthdate, nickname/avatar name) and collect additional profile information provided by you to personalize your profile (such as choosing the look of your avatar). This information will be combined with your account ID.
  • Shop: If you buy memberships and bundles, credits and diamonds on our websites, we process this information with your account data to provide you our Services. You can buy Habbo codes and earn credits on third party websites. (Learn more about “Habbo Shop” below.)
  • In-game chats, Habbo Groups forums: Please note that our Services offer chat, Habbo Groups forums, community environments or other tools that do not have a restricted audience. If you provide Personal Data when you use any of these features, that Personal Data may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party. If you choose to post any personal data to public forums on our Service, please understand that it is visible to others as noted above. To request removal of your Personal Data from a public forum on one of our Services, please contact Customer Support at https://help.habbo.com/.
  • Private Chat Messages: Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality. Please be aware that when you use the chat function, the information you disclose may be read, copied, collected or used by other users. Never share information or personal data that is harmful for yourself or others.
  • Friend list: We collect information about the people and groups you are connected to.
  • Information provided in relation to our customer service: When you contact support, we collect your contact details (your email address), information about your request (subject, description of your request, your relationship with Habbo whether you are a Habbo player or the parent of a Habbo and the topic that you want to talk about), your Habbo name and further info (optional) and attached files (optional).
  • Information Provided in relation to transaction and payment: When you make a transaction on Habbo (e.g. purchased items or memberships, your order details) we collect information which is related to your transaction, for example the payment method, status and date. We do not collect any card data, you will be redirected to an external payment provider for the transaction of your payment, we receive payment confirmation details from our payment provider. For more information please see the service specific information below.

2.2 PERSONAL DATA WE RECEIVE OR GENERATE FROM YOUR USE OF OUR SERVICES

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

  • Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your device(s) includes the type of your device, device IDs, online identifiers (your IP address), timestamp, geolocation data (based on your IP address), url visited, browser settings, screen resolution and other technical information.
  • Cookie data: As further described in our Cookie Notice (“Cookie Notice”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice.
  • Your usage: We collect information about how you use our Services. This information includes the actions you take within the game (e.g. your achievements (such as the level reached), the items purchased within our Service and the amount you spent in the Service, your friend list), the time and duration of your activity, and your interaction with advertisements (clicks, conversions and creative views). Furthermore, we collect information about the websites that led you to our Service. Part of this information will be stored in your account (such as your friends list and your in-game progress).

2.3. PERSONAL DATA WE COLLECT FROM THIRD PARTIES

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data may be provided by the following third parties:

  • Payment Providers: If you make an in-app or website payment, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any complete financial information (such as your full credit card information) but may receive information which is related to your transaction, for example the payment method, status and date.
  • Social Networks and connected third-party platforms: If you choose to connect our Service with your e.g. Facebook, Google, Twitter, Microsoft, Yahoo or Apple account by using your credentials with our log-in process, we receive certain information about you from third party platforms such as your social network identifier, first and last name, your email address, age-range and your authentication token. To learn more about which data is processed when you use these Services, please see the section with service specific information below.
  • Other third parties: We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes. To learn more about which data is processed when you use our Services, please see the section with service specific information below.

3. DO WE COLLECT DATA FROM MINORS?

The Services are not targeted towards, nor intended for use by anyone under the age of 13. Our terms of use prohibit users aged under 13 years from accessing Habbo and respective age ratings are set in app stores and implemented by the app store provider to enforce our terms of use. In the event that we learn that we have collected personal data from a user under 13 years of age, we will delete that data as quickly as possible. If you believe that a user might be under the age of 13, please contact our support team at Habbo Support.

4. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on which Service you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

PROVISION AND IMPROVEMENT OF OUR SERVICES

  • to allow you to use our Services
  • to facilitate in-game communication via chat
  • to create and manage your account
  • to remember your preferred game settings
  • to restore your account if you ever lose access
  • to communicate with you in context of account activation and password management, to simplify the registration process
  • to facilitate your purchase, to verify and confirm your payment
  • to facilitate content sharing on social networks
  • to provide technical support and respond to your requests
  • to identify and correct any bugs/errors
  • to indicate the popularity of our Services
  • to assess the quality of our Services
  • to understand and improve your online experience

PERSONALIZATION OF YOUR GAME EXPERIENCE

  • to remember your preferred game settings
  • to remember you next time you visit one of our Services

MARKETING AND ANALYTICS

  • to deliver (targeted and non-targeted) advertising in our Services
  • to show you advertisements for our Services on other websites or apps
  • to measure the effectiveness of advertising
  • to personalize advertising for you
  • to pay our business partners for the promotion of our Services
  • to send you marketing communications, including newsletters and push notifications, informing you about new content and in-game offers
  • to acquire new users on social media platforms

PREVENTION OF FRAUD AND ILLEGAL ACTIVITY

  • to investigate fraud and illegal behaviour in our Services
  • to enforce our policies and terms of use

COMPLIANCE WITH OUR LEGAL OR REGULATORY OBLIGATIONS

  • to determine the legal requirements for processing of your Personal Data (based on your location and your age)
  • to maintain records related to purchases
  • to respond to your requests related to your data subject rights
  • to comply with our legal obligations (e.g. tax and accounting obligations)
  • to inform you about any changes to this Privacy Notice
  • to prevent offensive language, abusive behavior in-game communication via chat

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data within our Services.

5. DO WE ENGAGE IN PROFILING ACTIVITIES?

If you consent to this, we use tracking mechanisms to track your Personal Data for profiling purposes. This allows us to serve relevant content to you and adjust our Services and ads to your interests. You have the right to object to this type of processing. You can also go to your in-game settings or cookie settings to review and amend your privacy choices related to this type of processing at any time.

ON WHICH LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

  • Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in the context of sending newsletters, personalized advertising, analytics, profiling. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your in-game settings or your cookie settings. Please note that this will not affect any processing carried out before you withdraw your consent.
  • Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are party, for example, where it is necessary for the creation and administration of your account, to process your in-game purchase and the associated payment, in context of customer service, to support the operation of the game or facilitate the delivery of requested services.
  • Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age, for tax and accounting purposes or legal disputes.
  • Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the Service provided to you or to provide you with a better user experience and we process your personal data to obtain statistics concerning popularity of our Services within the context of group company products and services.

Please see for additional information the section with service specific information below.

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments, technical support or customer support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

  • External service providers: We share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services, web/social analytics services, user notification and marketing services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
  • Payment providers: If you make in-app or website payments, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment providers’ privacy policies.
  • External advertising companies: With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you use our Services. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you may be redirected to the third-party advertiser’s environment over which the third party is in control.
  • Social networks and connected third-party platforms: If you wish to share certain content on social media, you will be asked to log-in with your social media platform credentials. In this case, the content you want to share (e.g. a screenshot from the game) will be sent to the respective social network or third-party platform. We have included a Facebook, Google, Microsoft, Twitter and Yahoo button on our website and Facebook button mobile applications and Apple login on our iOS mobile applications to enable users to integrate with their social media profiles as and when they see fit to do so. Such parties may capture some of your data that way. These parties are controllers of the data for their own purposes. Learn more about our marketing activities in the service specific section below.
  • Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests from public authorities, including law enforcement, government authorities, supervisory authorities or courts.
  • Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we share your data with. Furthermore, you can find the third parties your Personal Data be shared with by clicking on the following link: 3rd party list

WHERE WILL YOUR PERSONAL DATA BE PROCESSED?

In general, your Personal Data is stored on servers outside the European Union (EU)/the European Economic Area (EEA). We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

HOW DO WE PROTECT YOUR PERSONAL DATA?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise or defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see below for service specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

  • the right to access the personal data we hold about you
  • the right to request the update or correction of your personal data
  • the right to receive your personal data in a structured, commonly used and machine-readable format
  • the right to request the deletion of your personal data
  • the right to restrict the processing of your personal data
  • the right to withdraw your consent
RIGHT TO OBJECT

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, Providing your email address and other mandatory information as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example the Autoriteit Persoonsgegevens in the Netherlands.

HOW DO I REQUEST MY HABBO DATA?

The confidentiality of personal data and the protection of customer privacy are important, basic values in all of our operations. At Habbo, we maintain an extremely high level of data protection. We process your personal data only for appropriate purposes defined in advance, and only when it is necessary.

You have the right of access and right to data portability.

Below, you can find a step by step guide on how to request your Habbo data:

  1. log-in to your Habbo Account and click “Settings” button.
  2. Go to the ‘Account data’ tab.
  3. Click the ‘Request data’ button.
  4. We will notify you once the data is available. Please note that it may take several days for this to happen.

The link to access your data will be available for up to 10 days after the date it becomes available to download. If you want to cancel your data request, please go back to the ‘Account data’ tab, which is found in the help window. You can access the settings window by clicking the gear icon in the bottom right hand corner of your screen and clicking the ‘Cancel’ button.

HOW DO I DELETE MY HABBO ACCOUNT?

You have the right to request the deletion of your data. Below, you can find a step by step guide on how to delete your Habbo account:

  1. log-in to your Habbo Account and click “Settings” button.
  2. Go to the ‘Account data’ tab.
  3. Click the ‘Delete account’ button.
  4. Please note that it may take several days for your account to be deleted.

If you want to cancel your erasure request, please go back to the ‘Account data’ tab, which is found in the settings window. You can access the settings window by clicking the gear icon in the bottom right hand corner of your screen and then on the ‘Cancel’ button. Habbo may retain your account data after a deletion request due to legal or regulatory requirements or for the reasons stated in this Privacy Notice.

HOW CAN YOU CONTACT US?

If you have created a Habbo Account, you can exercise your “Right to Access” or “Right to Portability” or “Right to Erasure” options in your Account Data settings which are explained above. If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support or via email to: privacy@sulake.com.

HOW OFTEN DO WE UPDATE THIS PRIVACY NOTICE?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example you did not create an account, we will inform you with a banner or message on our Website.

This Privacy Notice was last updated on: 19.08.2021

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice. We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

  • Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
  • Category B - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D – Commercial information (such as purchase history)
  • Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
  • Category G – Geolocation data
  • Category H – Audio, electronic, visual, thermal, olfactory, or similar information. The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to data portability which enables you to request to transfer your personal data to another data controller.

Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request. Under The CCPA, when the data of a child who is under the age of 13 require parental consent.

ADDITIONAL INFORMATION FOR BRAZIL RESIDENTS

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime. In the case of children younger than 13 years old, specific and prominent consent must be given by a parent or person responsible for the child.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

HABBO

HOSTING AND CONTENT DELIVERY:

Habbo is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

CREATION/ADMINISTRATION OF YOUR ACCOUNT:

In order to play Habbo, you have to create an account. We store your account data (log-in credentials, email address, password, birthdate, account ID, avatar and avatar name) to allow you to log in on different devices and to enable socializing and communication with the other players, based on the performance of a contract.

Furthermore, we will store your avatar’s in-game progress, your virtual assets (rooms, clothes, furniture), and your friends list in your account in order to make the multiplayer/online game work.

If you choose to register using your e.g. Facebook, Google, Microsoft, Yahoo or Apple account, we receive certain information about you from the respective third-party provider like e.g. your name, your profile picture, your email address, age range and an authentication token. This information will be stored for your account’s lifetime to ensure that your Habbo account is connected with the third-party platform and that you can log-in with your credentials.

Your account data will be stored for as long as your account exists, based on the performance of a contract. You can delete your Habbo account at any time, for example by submitting a deletion request to our support team using the “Right to Erasure” feature within the game or using the contact feature on our Service Website or by contacting our Data Protection Officer through sending an email to privacy@sulake.com. Habbo may retain your account data after a deletion request due to legal or regulatory requirements or for the reasons stated in this Privacy Notice.

FACEBOOK CONNECT

We’re offering you the opportunity to sign up for our Services through Facebook Connect. In order to do this, you will be redirected to Facebook where you can log in using your Facebook user data. Your Facebook account will then be linked to our Services.

Depending on your Facebook settings, linking your account will allow the following data to be transmitted to us and/or retrieved by us: email address, name, and other data that you have set to the public on your Facebook profile.

We shall only use this information for identification purposes and contract processing. For more information on Facebook Connect and the privacy settings, please refer to the Privacy Policy and Terms of Use of Facebook Inc. https://www.facebook.com/policy.php.

If you use Facebook Connect to register for and log into an account, your Personal Data will be transmitted to Facebook, Inc. 1601 Willow Road Menlo Park, California 94025 in the United States.

You can unlink the accounts at any time and revoke the transfer of data with future effect by changing your settings on Facebook (here) and through your Habbo Account Settings.

GOOGLE BUTTON

Our website also employs the Google Button, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (Google). The link can be identified by the “SIGN IN WITH GOOGLE” symbol against a white or color background. We’re offering you the opportunity to sign up for our Services through Google Button. In order to do this, you will be redirected to Google where you can log in using your Google user data. Your Google account will then be linked to our Services. Depending on your Google settings, linking your account will allow the following data to be transmitted to us and/or retrieved by us: email address and other personal information, including any personal information you have made publicly available on your Google profile. We shall only use this information for identification purposes and contract processing. For more information on Google and the privacy settings, please refer to the Privacy Policy and Terms of Use of Google Inc. The purpose and scope of data collection via Google, the processing and use of such data, as well as your rights thereof and personal settings regarding privacy protection can be found in the Google privacy settings section https://policies.google.com/privacy?hl=en-US If a user is a Google member and does not wish to have their data collected and linked to their saved Google member data via our web presence, the user must log out of their Google Plus account before visiting our websites. You can unlink the accounts at any time and revoke the transfer of data with future effect by changing your settings on Google (here).

TWITTER

We’re offering you the opportunity to sign up for our Services through Twitter. In order to do this, you will be redirected to Twitter where you can log in using your Twitter user data. Your Twitter account will then be linked to our Services. Depending on your Twitter settings, linking your account will allow the following data to be transmitted to us and/or retrieved by us: email address, name, and other data that you have set to the public on your Twitter profile. We shall only use this information for identification purposes and contract processing. For more information on Twitter and the privacy settings, please refer to the Twitter Privacy Policy at: https://twitter.com/en/privacy If you use Twitter (Twitter is an US based company) to register for and log into an account, your Personal Data will be transmitted to One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; however, personal data may also be processed by Twitter Inc., 1355 Market Street, Suite 900, San Francisco CA 94103, USA. You can unlink the accounts at any time and revoke the transfer of data with future effect by changing your settings on Twitter (here).

YAHOO, MICROSOFT AND APPLE

When you sign in to the Habbo using your Yahoo, Microsoft and Apple credentials such service sends us your email address associated with the credentials you've used and other data that you have set public on your Yahoo, Microsoft and Apple Account. For more information on Yahoo and the privacy settings, please refer to the Yahoo Privacy Policy at: https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/index.html For more information on Microsoft and the privacy settings, please refer to the Microsoft Privacy Policy at: https://privacy.microsoft.com/en-gb/privacystatement For more information on Apple and the privacy settings, please refer to the Apple Privacy Policy at: https://www.apple.com/legal/privacy/en-ww/

CUSTOMER SERVICE:

If you contact us for customer support, an external customer service company will process your email address and/or your name (optional), and the content of your request. In order to provide you with support, this information will be processed together with your device information (model, OS, game language, carrier), the user ID, user segment, and the last steps taken within the game. The request history is stored for your account’s lifetime to enable handling of newer requests based on your previous request and to improve our services.

We process this data on the basis of the performance of a contract as far as the information is required to answer your request. The continued storage of your request history is based on our legitimate interest, in order to improve our services and for potential legal disputes.

PAYMENTS:

If you make in-app purchases, you will be redirected to an external payment provider for the transaction of your payment. The transactions will be processed by the third-party payment provider. While we do not collect and do not receive any financial data (such as your bank account data), we collect or receive from third-party payment providers the following information related to your transaction: the purchased amount and item, the price and currency, your country, your IP address, e-mail, phone number (SMS purchases only), device information (user agent), time stamp, url visited, payment method, expiration date and last four digits of your credit card (credit card purchases only), payment/transaction id, and the status of your payment.

We store this information for at least 7 years or upto 10 years depending on the service provider. We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your in-game purchase.

FORUM AND CHATS:

If you use the chat feature within our game, your message will be processed, together with your user ID and your avatar, the timestamp, recipients of your message or room ID (if you post your message in a public chat room). This process is based on the performance of a contract. The content of your messages will also be processed by an external content moderation service in order to detect and filter offensive language or violations of our terms and conditions and to set automatic sanctions (temporary muting) to offenders. This process is based on our legitimate interests. Please be aware that when you use the chat function, the information you disclose may be read, copied, collected or used by other users. Never share information or personal data that is harmful for yourself or others.

HABBO SHOP:

Get Prepaid:

If you want to buy Habbo Credits, you could buy it on third party websites. Please check third-party service providers’ privacy policies.

Earn Credits:

You can earn Habbo Credits through interactions with a third-party service. Please check third-party service providers’ privacy policies.

LOGGING OF ALL IN-GAME ACTIVITIES:

In order to help you with any issues you might have with our game, to understand how our software works, and to investigate fraud and illegal behaviour in our game, we collect and store all the steps you take within Habbo, together with the following information: your account ID, your IP address and device information (user agent or mobile device information) in our logs which will be deleted after 60 days. This process is based on our legitimate interests to be able to analyze and solve any potential issue with our Services.

ACCOUNT SETTINGS

1. Privacy

Through Privacy settings, you can control:

  • Profile Visibility;
  • Online Status;
  • Follow me Settings;
  • Friend Requests;
  • Offline Messaging;
  • Email Notifications;
  • Your GDPR Rights.

2. Account Protection

You can protect your account from unwanted access by setting two safety questions. When someone tries to log in from a new computer, they will have to answer the safety questions correctly .

If we detect that your account may have been compromised, your account will be locked. Any critical functionality such as trading will be disabled until you unlock the account or log in from a trusted location.

ANALYTICS:

We use internal and external analytics services to understand which features and ads you like in Habbo and how you use or interact with them. The analytics data helps us to improve the game for you, to develop new items, to find crashes and issues in the game, and help third-party advertising companies to measure and improve the effectiveness of their campaigns placed in Habbo.

For Internal Analytics Services, we process your in-game activities (such as your in-game purchases), device information and data generated from the use of the Services, such as technical data generated when playing Habbo. We store the (personalized) analytics data for three years.

We process this information based on your consent.

For external analytics (such as Google Analytics), we process information about your device, request data (including the URL of the current webpage and the website visited before) and special event data. We process this information to better understand how you use our Services and to improve our websites. By activating IP anonymisation on this Website, the IP address is shortened prior to transmission within the EEA or in other states party to the Agreement on the EEA.

We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access Habbo for the first time.

THIRD-PARTY ADVERTISING WITHIN OUR GAME:

In Habbo, we show advertising from different advertising companies. These advertisements can be personalized or non-personal content related ads. In order to show you personalized ads and only if you have provided your consent, we will use Web Ads from Google in our Service Website which enables Google and third-party advertising companies to collect your Personal Data. The collected data includes your device information, like IP address and device identifiers, your location data, your in-game activity (such as purchase events and your game play sessions), information regarding the delivery of ads and your interaction with them.

You can adjust your privacy preferences at any time in your cookie settings or game settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.

For some of the ads shown in Habbo, you can earn virtual currency if you watch the ad (“rewarded ad”). In order to credit the virtual currency to your account, we process the following Personal Data: your device type, device language and country.

This process is based on our and third-party advertising companies’ consent, to encourage you to watch the ad and spend money for the product shown in the ad.

IN-GAME OFFERS:

We also process your personal data in order to inform you about our in-game offers. Different in-game items will be offered to different user segments. For this purpose, we process the following information: your age, the account age, avatar gender, whether you are a Habbo Club member, the amount of days since Habbo Club membership ended, the amount of visits and the amount of In-App or website purchases. This information is collected for the purpose of analyzing whether specific in-game offers are particularly relevant for certain user segments and stored for the period of three years. In this context, we only look at data in an aggregated form without reference to you. Based on your information, you may fall into a specific user segment and thereby receive in-game offers that are more relevant to you. This process is based on your consent.

SOCIAL MEDIA SHARING SERVICE

You can share content from Habbo with your friends via social media by clicking on the social media share button and using your social media platform credentials. Following your request, a screenshot from the game will be shared with the social media platform you wish to share your content with. We process this data based on your consent, which you provide by choosing it on Cookie settings to share content from Habbo via social media.

AFFILIATE SYSTEM

Third-party website owners can participate in our affiliate program to earn a revenue share of the purchases the users they brought into the game made in Habbo.

PUSH NOTIFICATIONS

Based on your consent, we may show you push notifications to inform you of new content and offers in Habbo. For this purpose, the user notification service will process information about the status of the push notification (notification received/viewed) and device information. You can turn off the push notifications in your account settings at any time.

NEWSLETTERS

When you sign up for an account in Habbo, you will be asked to provide your consent for the delivery of newsletters. In this context, we process the following Personal Data such as your email address, your last log-in, your name, language, country, your user ID. You can cancel your subscription to our newsletter at any time over the corresponding link which appears at the end of every newsletter (or opt out through the in-game settings).

THIRD PARTIES:

If you click here, you will see an overview of the third parties we share your Personal Data with, or that may share your Personal Data with us.

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