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Privacy Policy

In compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (GDPR), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), we inform you of the following aspects:

1. Who is responsible for the processing of your data?

  • Responsible: LEVEL UP [GAME DEV HUB] S.L.U
  • NIF/CIF: B09832395
  • Registered Office: C/ Martí Alsina 28, 08031 Barcelona
  • Contact person: Roger Montserrat Ribes
  • Contact telephone numbers: 93 418 39 19 · 618 120 655
  • Email: roger@game-levelup.com

Currently, no Data Protection Officer (DPO) has been appointed because he is not legally obliged to do so. However, if you have any questions or queries regarding the protection of your data, you can use the contact details indicated above.

2. For what purpose do we process your personal data?

Your data will be collected and processed exclusively for specific, explicit and legitimate purposes, without being further processed in a manner incompatible with these purposes. Specifically:

  1. Provision of services and billing: To manage the contractual and/or commercial relationship we have with you, including the handling of queries and the billing of the contracted services.
  2. Commercial communications and offers: Sending, by electronic or postal means, commercial and advertising communications related to our services and activities, provided that there is a legal basis that protects it (consent or legitimate interest for customers).
  3. Management of subscriptions or newsletters: If you decide to subscribe to receive our news, events and promotions, we will process your data for the management of these subscriptions and the periodic sending of information.
  4. Participation in surveys and promotional events: To collect your opinion through satisfaction surveys, organize raffles or events, always with your consent or legitimate interest.
  5. Compliance with legal obligations: Retain and/or disclose your personal data to the extent necessary for compliance with our legal obligations and/or in response to requests from public authorities.

Automated decisions will not be made based solely on automated processing that produces legal or other significant effects for the data subject, unless they are necessary for the provision of a specific service and we have previously notified them.

3. What is the legal basis for the processing of your data?

The processing of your data is based on:

  • Performance of a contract (Art. 6(1)(b) GDPR): If you request our services, we need to process your data in order to enter into and manage the contractual relationship.
  • Compliance with legal obligations (art. 6.1.c GDPR): For example, for accounting and tax obligations, invoicing, or meeting requirements of public bodies.
  • Legitimate interest (art. 6.1.f GDPR): In the case of commercial communications addressed to customers, as long as they are related to services or products similar to those contracted. You may object to receiving such communications at any time.
  • Consent (art. 6.1.a GDPR): For purposes such as sending newsletters, surveys or commercial communications when there is no prior contractual relationship. This consent may be revoked at any time, without affecting the lawfulness of the processing carried out previously.

4. How long will we keep your data?

We will retain your personal data:

  • For the duration of the contractual relationship: Until the end of the requested service or the cancellation as a customer.
  • For legally required periods: For example, billing data will be retained for at least the period set by tax and commercial regulations (usually 4-6 years).
  • Until you withdraw your consent or request its deletion (in cases based on consent, such as newsletters or surveys).
  • Once these deadlines have expired, your data will be securely blocked or deleted , unless it must be kept for the establishment, exercise or defence of claims.

5. What are your rights when you provide us with your data?

You may exercise the following rights at any time:

  1. Access: To know what personal data we process and the purpose of such processing.
  2. Rectification: Request the modification of your personal data when they are inaccurate or incomplete.
  3. Erasure (right to be forgotten): Request the deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
  4. Opposition: Object to the processing of your data based on legitimate interest or public interest, except for compelling legitimate reasons or for the defence of possible claims.
  5. Restriction of processing: Request that we restrict the processing of your data when you contest the accuracy, lawfulness or necessity of the data, in which case we will only keep it for the exercise or defence of claims.
  6. Portability: Receive your personal data in a structured, commonly used and machine-readable format, and transmit them to another controller when the processing is based on consent or the performance of a contract and is carried out by automated means.
  7. Withdrawal of consent: In processing based on consent, you may withdraw consent at any time, without affecting the lawfulness of the previous processing.

To exercise your rights, you can send a request accompanied by a copy of a document proving your identity (ID card, passport, etc.) to:

  • Postal address: LEVEL UP [GAME DEV HUB] S.L.U., C/ Martí Alsina 28, 08031 Barcelona
  • Email: roger@game-levelup.com

We will respond to you within the legally established deadlines. Likewise, if you consider that we have not processed your personal data in accordance with the regulations, you have the right to file a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es.

6. To whom will your data be communicated?

  • Your data may be communicated to other companies in the group for internal administrative purposes directly related to the provision of the service.
  • If necessary, they will be communicated to third-party providers acting as data processors (e.g. accounting consultancy, hosting services, mailing platforms, banks), always in accordance with a data processing contract that guarantees the confidentiality and security of the information.
  • They may be transferred to the Public Administration or other competent authorities when required by the regulations (legal obligation).

In any case, only the data that is strictly necessary and for the legitimate purposes indicated above will be communicated.

7. Are there international data transfers?

LEVEL UP [GAME DEV HUB] S.L.U. informs you that, at present, no transfers of personal data are made outside the European Economic Area (EEA), or only when:

  • The recipients are located in countries with an adequate level of protection recognized by the European Commission.
  • There are Standard Contractual Clauses approved by the European Commission, signed with the provider, which offer adequate guarantees in terms of data protection.

In the event that services outside the EEA are contracted in the future, you will be informed in a timely manner and the necessary measures will be taken to ensure an adequate level of protection in accordance with EU regulations.

Note: Previously there was the “Privacy Shield” framework between the EU and the US, declared invalid by the CJEU in 2020. Therefore, any transfer to U.S. suppliers is currently based on Standard Contractual Clauses and, where applicable, on the appropriate evaluation and additional guarantees.

8. What security measures do we apply?

LEVEL UP [GAME DEV HUB] S.L.U. undertakes to treat your data in an absolutely confidential manner and to implement the appropriate technical and organisational security measures to protect them against unauthorised access, alteration, loss or destruction. These include:

  • Access control and encrypted passwords.
  • Encrypted communications using HTTPS on the web.
  • Regular backups to ensure information recovery in the event of an incident.
  • Training and awareness of staff on data protection and security.

However, no system is 100% invulnerable; If any security incident occurs, we will notify the competent authority and/or the affected persons, as required by the regulations.

9. Cookies Policy

In the event that this website uses its own or third-party cookies, we will inform you through a banner or notice on your first visit and/or through a specific Cookie Policy , which will detail the types of cookies, their purposes and will request, if applicable, your consent.

9.1 What are cookies?

Cookies are small text files that are downloaded to the user’s device (computer, smartphone, tablet) when accessing certain websites. They allow, among other things, to store and retrieve information about the browsing habits of a user or their computer and, depending on the information they contain and the way in which the equipment is used, they can be used to recognize the user.

9.2 What types of cookies does this website use?

  1. Technical cookies (necessary): They allow navigation through the website and the use of the different services that exist on it (for example, to control traffic, identify the session or access restricted access parts).
  2. Preference or personalization cookies: They allow us to remember information so that the user can access the service with certain characteristics that may differentiate their experience (such as language, browser type or regional configuration).
  3. Analysis or measurement cookies: They collect information on the use of the website (for example, to measure user activity and compile statistics).
  4. Third-party cookies: These may be installed via the website by third parties (such as analytics service providers, social networks or external content).

Note: Tailor this list to the cookies you actually use. If you do not use all of these categories, please delete them or describe them briefly, for example by indicating the name of the cookie, provider, purpose and duration.

9.3 Consent

When accessing this website, a cookie or banner notice will be displayed that allows:

  • Accept the installation of cookies (all or selected).
  • Configure which cookies you want to allow.
  • Obtain more information in this cookie policy.

At any time, the user can withdraw or modify the consent for the use of cookies through the settings of their browser or the options in our settings panel (if available).

9.4 How do I disable or delete cookies?

The user can allow, block or delete the cookies installed on their computer by configuring the browser options. Below are links to documentation for the most common browsers:

Note: If you disable certain cookies, the quality and speed of the service may decrease or even stop working some of the functionalities offered on the website.

5. Updates and changes to the cookie policy

This Cookies Policy may be modified according to regulatory requirements or changes in the configuration of the services used on the website. Therefore, users are advised to check it periodically.

10. How do we obtain your data?

Typically, we obtain personal data directly from you, through:

  • Contact or registration forms on our website.
  • Emails or communications you send to us.
  • Subscriptions to newsletters or other services.
  • Paper forms, phone calls, surveys, interviews, etc.

The categories of data that are processed may include:

  • Identification data (name, surname, ID card, etc.).
  • Contact details (postal address, email, telephone).
  • Economic/fiscal data (banking, invoicing, etc.).
  • Employment data (in the case of staff, suppliers or candidates).

LEVEL UP [GAME DEV HUB] S.L.U. does not process sensitive or specially protected data (health, ideology, religion, sexual orientation, etc.) in a systematic manner. If at any time we need to collect this information, we will ask you explicitly and with a legal basis that justifies it.

11. Consent and revocation mechanisms

  • By ticking the corresponding boxes, or by filling in and sending forms on the website, the interested party accepts this privacy policy and, where appropriate, grants their consent for processing based on said consent.
  • If you do not wish to receive further commercial communications, an immediate unsubscribe link will be available in each email, or you can write to roger@game-levelup.com indicating “Unsubscribe Communications” in the subject line.
  • At any time, you may withdraw the consent given, without affecting the lawfulness of the processing prior to such withdrawal.

Last updated: 14-03-2025


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