Privacy Policy

1. Who will process your personal data?

  • Holder: Playvalve S.L.
  • DPO: ECIJA Legal & Compliance. Torre de Cristal, Paseo de la Castellana, 259C, 28046 Madrid

Playvalve S.L., (hereinafter, “FAKTUALLY”) is responsible for the privacy of its users along with the protection and security of their personal data. Therefore, FAKTUALLY informs the user about the way it collects, processes and protects the personal data that the users submit when making use of the services provided by the website faktually.com (hereinafter, the “Web Site”).

The user must carefully read through this privacy policy which has been written plainly and simply to facilitate the understanding of these responsibilities; so that the user may determine freely and voluntarily whether he or she wishes to submit his or her personal data to FAKTUALLY.

Additionally, the user guarantees that the submitted data is truthful, accurate, full and kept up to date, and that he or she shall be responsible for any damage, whether direct or indirect, that may derive from a violation of such data. In the event that the delivered data belongs to a third party, the user guarantees that he or she has informed said third party of the aspects contained in this document and has obtained authorisation to submit his or her personal data to FAKTUALLY for the indicated purposes.

2. How are users informed about the processing of their data by Facebook

For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook’s privacy policy: https://www.facebook.com/about/privacy/.

When authenticating through a third party service, the users are asked to keep in mind the applicable Terms of Use, as well as the Rules for Data Use that Facebook states. Those terms are explained in the following link: https://www.facebook.com/privacy/explanation/

Shall users decide not to use their Facebook accounts in order to render our website’s services, they may cancel this connection within their privacy settings through this link: https://www.facebook.com/settings?tab=applications

3. Server Log-Files

During every visit to our Web Site, information about IP address, access-provider, referring URL, date/time, browser type, version, operating system, amount and state of transferred data is stored in the web server log files.

We use the log data without any other personal or pseudonymous profiling, as required by law, for the purpose of the operation, security and optimization of our servers only.

4. For what purposes do we process your data?

FAKTUALLY provides engaging entertainment content through the Web Site (hereinafter, “the services”) for the user, including quizzes and personality tests.
FAKTUALLY shall process the personal data of the user for the following specific purposes:

  1. Provision of our services and contents/functions.
  2. Response to service, contact requests, inquiries and other communication with users.
  3. Marketing, advertising and market research.
  4. To create anonymised statistical reports with respect to the habits of access and the activity of the users of our services, pursuant to our cookies policy.
  5. To comply with legal obligations.

5. On what grounds are we legitimated to process?

The legal ground for the processing of your data is based on the aforementioned consent, the performance of contractual services, and legitimate service interest to comply with legal requirements.

6. International data transfers

Furthermore, for the sole purpose of compliance with the services offered to users, FAKTUALLY will transfer certain data to the following entities, guaranteeing in all cases that they have the adequate or appropriate guarantees to process the data:

  • Amazon: P.O. Box 81226, Seattle, WA 98108-1226
  • Redis Labs: 700 E El Camino Real Suite 250, Mountain View, CA 94040 Tel: +1 (415)930-9666, USA
  • Cloudflare, Inc: 101 Townsend St, San Francisco, CA 94107, USA
  • Google Analytics: 600 Amphitheatre Parkway, Mountain View, CA 94043, USA
  • Heroku (Salesforce): One Market Streer, Suite 300, San Francisco, CA 94105, USA
  • FaceApp: wireless lab OOO 16 Avtovskaya 401 Saint-Petersburg, 198096, Russia.
  • Pho.to: VicMan LLC, Moscow, Rusia

International data transfers to the United States are based on the adequacy decision of the European Commission, established by the Privacy Shield framework, whereby data recipient organisations are recognised as ensuring an adequate level of data protection.

For the remaining cases, FAKTUALLY has a standard Data Processing Agreement satisfying requisites established by European authorities. Therefore, FAKTUALLY guarantees that these suppliers shall always comply with the applicable legislation and that under no circumstance shall FAKTUALLY process personal data for purposes other than those indicated in this Privacy Policy.

7. What are your rights as data subject?

The user may, at any time and free of charge, exercise his or her rights: to access, to rectification, to erasure, to restriction, to data portability and to object by raising a request to the email addresses listed under Section 1, under the terms established by the current legislation.

The user is informed that where he or she considers that FAKTUALLY has violated or may have violated the rights granted by the applicable legislation on data protection, he or she may file a formal complaint to the Spanish Data Protection Authority (Agencia Española de Protección de Datos, that can be contacted through the following link: https://www.aepd.es)

8. Data Retention Policy

FAKTUALLY shall store the personal data of the users for as long as it is deemed necessary to accomplish the purposes for which they were collected, and specifically in the follows terms:

  • Data facilitated directly by the user will only be processed by FAKTUALLY so far as the user uses the Service.
  • Only users’ quiz results (and associated meta-data) will be stored. Results contain a irreversible user hash used in order to identify users’ results upon deletion requests. This data will be conserved in a restricted manner during a period of 5 years in order to satisfy any potential legal obligations and/or responsibilities derived from their treatment.
  • Any IP addresses will be stored for a maximum of one month.
  • The photo processing by FaceApp is stored temporarily and is then deleted within 5 days.
  • Finally, information proceeding from cookies will be conserved for a maximum period of 13 months. In those cases where the remittance of commercial information has been consented, FAKTUALLY shall process the personal data until the data subject withdraws his or her consent or objects to the processing.

9. Analytics and marketing tools

Within our Service we have embed third-party (hereinafter “Marketing Provider”) marketing and ad technology in order to improve the efficiency of our marketing efforts and the relevance of the advertising presented to consumers, as well as for marketing of advertising space within our Service.

Marketing Provider might use “Pixel Tags” (small invisible images) to collect information. Through the use of Pixel-Tags simple actions such as the visitor traffic to the Website can be pseudonymously recorded and collected. The pseudonymous information might also be stored in cookies on your device, including technical information like your Browser or OS, details of how you used our Service and interacted with contents displayed by the Marketing Provider. This information might be combined with such data collected from other sources or used in order to display user tailored advertising content on other websites and within other services.

The following is a list, that shows the Re/Marketing Providers we work with and their privacy policies, with detailed information on their data collection, including ways to opt-out from their data collection.

10. Necessary Amendments

FAKTUALLY reserves the right to modify its data protection and security data at any time without prior notice, always under Spain’s current and applicable personal data protection legislation.

© 2019. FAKTUALLY. All rights reserved.