Privacy policy
The purpose of this privacy policy:
This Privacy Policy ("Privacy Policy") will explain to you what personal data we collect, how and why we collect them, the legal basis for processing them, how long we retain them, to whom we disclose them, as well as inform you about your rights and the procedure for exercising them and provide other relevant and important information related to the processing of your personal data.
This Privacy Policy applies to you when you order CityFun games, newsletters, or consent to receive offers from CityFun partners regarding participation in contests and games, as well as in cases where you are a CityFun game author, and when we process your personal data as a CityFun author/supplier/partner (legal entity) employee or representative. This Privacy Policy also describes your rights as a data subject and our obligations as a data controller.
Data controller: Enjoy events, MB, company code: 302334471, registered address: Mažvydo g. 16/27 Vilnius, Republic of Lithuania ("we" or "CityFun"). You will find our detailed contact information in section XIII of this Privacy Policy. Personal data means all information related to an individual whose identity is established or can be established ("Data"), such as your name, phone number, or email address. Please review the information provided in this privacy policy carefully and familiarize yourself with it in detail before submitting your personal data to us. Supervisory authorities: Information Society Development Committee under the Ministry of Transport and Communications and State Data Protection Inspectorate. Data about the data controller is accumulated and stored at the Vilnius branch of the State Enterprise "Center of Registers". We confirm that the data of visitors to the data controller's websites and social media accounts will be collected in compliance with the requirements of applicable European Union and Republic of Lithuania legislation and instructions of supervisory authorities. All reasonable technical and administrative measures are applied to ensure the protection of data collected about visitors to websites and social media accounts from loss, unauthorized use, and changes. The employees of the data controller have undertaken in writing not to disclose and distribute the information obtained at work, including information about website visitors, to third parties.
For your convenience, we have divided this Privacy Policy into sections, so that you can easily find relevant information for you.
Below we provide the content of this Privacy Policy:
Section I: Processing of personal data for direct marketing purposes (sending CityFun newsletters, offers from partners regarding participation in contests and games);
Section II: Processing of personal data of CityFun players;
Section III: Processing of personal data of authors of CityFun games;
Section IV: Processing of personal data based on inquiries sent by you;
Section V: Processing of personal data of suppliers, partners (legal entities) employees, or other representatives of CityFun;
Section VI: Security;
Section VII: Recipients of your personal data;
Section VIII: How we process your personal data;
Section IX: Your rights related to your personal data;
Section X: Submission of a request to exercise data subject rights;
Section XI: Regarding children's personal data;
Section XII: Policy changes and our contact information.
I. Processing of personal data for direct marketing purposes
1.1. Types of processed personal data. If you have given us consent to receive direct marketing communications (CityFun newsletters and/or CityFun partner offers for participation in contests and games) on our website, we process your email address. The source of all these data is you.
1.2. Consequences of not providing data. Providing us with your email address is completely voluntary, but please note that if you do not provide us with your email address, we will not be able to send you CityFun newsletters and/or offers for participation in contests and games.
1.3. Purposes of personal data processing. When you consent to receive CityFun newsletters and/or CityFun partner offers for participation in contests and games, we process your personal data for direct marketing purposes.
1.4. Legal basis for personal data processing. We process the personal data you provided based on your consent. Please note that you have the right to withdraw your consent for receiving direct marketing communications at any time - you can do so by clicking on the appropriate link in each received email containing direct marketing content, or by submitting a request to us by email or in any other way as specified in section X of this Privacy Policy.
1.5. The term of processing of your personal data.
We process your personal data for the entire period during which your consent for receiving direct marketing messages is valid, but no longer than one year from the receipt of your consent. Information proving your consent for data processing is stored for 2 years after the revocation of consent or the expiration of its validity. After the storage period of your personal data has expired, we securely destroy your personal data.
II. Processing of CityFun players' personal data
2.1. Types of processed personal data: Name, phone number, email address; Player's geographic location, duration and time of played game; Payment information (your name, surname; account number; date of transaction; transaction amount; purpose, etc.); Information about unforeseen situations that you inform us about through the notifications of our application/website; Identification data of the device on which the CityFun application/mobile website is installed.
2.2. Consequences of not providing data. Please note that if you do not provide the personal data necessary for purchasing and playing the CityFun game (personal data specified in section 2.1.), we will not be able to provide the game organization service.
2.3. Purposes of Personal Data Processing. We process your personal data for the following purposes:
We collect and process personal data to connect game creators with players in order to promote traveling and exploring Lithuania;
Geographical location data is collected only when the "CityFun" mobile app/website version is enabled. Data collection is stopped when the "CityFun" app/website is disabled. We may use geographical location data to facilitate player participation in the game; Your name, phone number, and email address will be used for communication with you;
We collect payment data to process payment for game organizing services;
Customer service data is collected on a case-by-case basis, as needed and situationally, and is stored for quality service purposes.
Note that you have the right to withdraw your consent for CityFun to process (store) your personal data for legitimate CityFun interests at any time, based on the procedure provided in Section X of this Privacy Policy; For the purposes of entering into and administering the agreement for your participation in CityFun games, and for the lawful basis of such agreement, your personal data is processed. Your personal data confirming the economic operation (if applicable) is also stored on the basis that processing of this data is necessary to fulfill the legal obligation imposed on the data controller - to comply with payment and other payment formalization and accounting rules; Please be informed that you have the right to withdraw your consent at any time (you can do so by submitting a request to us according to the procedure set out in Section X of this Privacy Policy).
2.4. Terms of processing your personal data: Your data will be stored as long as your player account is active. If your account is closed, the data will be deleted (according to the rules set out in this section) from the database. An exception is made for cases where data must be retained for tax, dispute resolution, or fraud prevention purposes; Financial information data about player's use of game organizing services will be stored for 3 years from the last game; Accounting information data will be stored for 7 years from the last game; In case of suspicions of criminal activity, fraud or false information submission, data will be stored for 10 years; In case of payment disputes, information will be stored until the situation is resolved or the statute of limitations expires; Game information is stored for 3 years, after which the information becomes anonymous; Please note that deleting the CityFun app from your device does not remove your data from the system; After the expiration of the storage period of your personal data, we securely destroy your personal data.
III. Processing of personal data of CityFun game authors
3.1. Types of processed personal data:
Name, surname, email address, phone number, residential address; Author's identification number Payment-related data (your name, surname; account number; transaction date; transaction amount; purpose, etc.).
Financial information related to game creation services is not considered as personal information if game authors provide the service on an individual basis. All information where the data source is you or third parties, such as your name, surname, company, position, and contact information obtained from publicly available sources on the internet (websites and/or social media accounts) is not considered personal information.
3.2. Consequences of not providing data. Please be informed that if you do not provide the personal data required for CityFun game content creation, we will not be able to publish the games you create and consequently attract visitors to order your created games. If you do not provide the data necessary for payment processing (if applicable), we will not be able to settle with you for the services/content provided by you.
3.3. Purposes of personal data processing. We collect and process personal data in order to connect game participants with game creators to promote travel and exploration in Lithuania; For communication purposes with you - to invite you to become a CityFun game author. The author's name, surname, and a brief description of the activity are displayed in the CityFun application/mobile website version for customers; You will receive reports from your CityFun author account that will indicate the ratings of your games. The report and game ratings are necessary to ensure good customer service. For the creation of an agreement regarding your participation in the creation of CityFun games and for the proper administration, accounting, and implementation of such an agreement; For the promotion of you as an author creating CityFun games, and for the purposes of CityFun game advertising.
3.4. Legal basis for processing personal data: Personal data is processed in order to fulfill the agreement with the author. The necessary condition for using CityFun services is the author's consent that their personal data will be collected and processed; For communication purposes, your personal data is processed based on our legitimate interest - to invite relevant authors to CityFun and successfully create CityFun games by attracting as many participants as possible. We note that you have the right to withdraw your consent for CityFun to process (store) your specified personal data based on CityFun's legitimate interest for specific reasons at any time (the right to withdraw consent is implemented in accordance with the procedure provided in Section X of this Privacy Policy); For the purposes of creating an agreement regarding your participation in the development of CityFun games and for the proper administration and implementation of such agreement, your personal data is processed on the legal basis of the concluded agreement. Personal data confirming the economic transaction (if applicable) is also stored on the basis that it is necessary for the data controller to fulfill its legal obligation to comply with payment and other payment formalization and accounting rules; For the purposes of publication and promotion of CityFun games as an author, your personal data is processed based on your consent given to us as a legal basis - we inform you that you have the right to withdraw your consent at any time (you can do this by submitting a request to us in accordance with the procedure set forth in Section X of this Privacy Policy). Personal data may also be processed based on legitimate legal interests, such as investigating and identifying fraudulent payments.
3.5. Terms of processing your personal data:
You can view and edit your personal data in your CityFun author account; Your personal data will be stored as long as your author account is active. If your account is closed, personal data will be stored for an additional 3 years; Personal data for accounting purposes will be stored for 7 years; In case of suspected administrative or criminal activity, fraud or false information, data will be stored for 10 years; In case of disputes, data must be stored until the requirements are met or the validity period of such requirements expires; Any requests for issuance of personal information records, data transfer or deletion submitted by email will be responded to within one month.
IV. Processing of personal data based on inquiries submitted by you
4.1. Types of processed personal data. When you submit an inquiry to us, we process the personal data you provided in your inquiry, which may include your name, surname, contact information (e.g., email address, phone number), and other information specified in the inquiry. The source of all this data is you.
4.2. Consequences of not providing data.
Formulating and submitting your request to us is entirely voluntary, and you are not obligated to do so. However, please be informed that if you do not provide us with the data specified above, it may be impossible for us to respond to your question or our ability to do so may be hindered.
4.3. Purposes of personal data processing.
We process your personal data in order to contact you and respond to the questions you have submitted in your request.
4.4. Legal basis for personal data processing.
The personal data you have provided are processed on the basis of your consent. By voluntarily and actively submitting your request to us, you express your consent for your personal data to be processed for the respective purpose of responding to your questions.
4.5. Term of personal data processing.
We process your personal data for the purpose of responding to your request until your questions are answered. Information confirming your consent for data processing is stored for 2 years after the withdrawal of consent or the expiration of its validity. After the storage period of your personal data has expired, we securely destroy your personal data.
V. Processing of personal data of suppliers, partners (legal entities) employees or other representatives.
5.1. Types of processed personal data.
The following personal data of you, as an employee or other representative of a supplier/partner (goods supplier, professional or other service provider, lessor, etc., hereinafter referred to as "Partner"), are processed by CityFun for the purpose of concluding and performing contracts:
Name and surname;
Contact information (phone number, email address);
Company, position;
Signatures (when objectively necessary, for example, when signing contracts, invoices, and other documents related to business activities).
The source of this personal data is you and third parties, for example, your name, surname, company, position, and contact information may be obtained from publicly available sources on the internet (e.g., Partner's website), and we may also obtain your personal data from the Partner.
5.2. Consequences of Failure to Provide Data.
If you fail to provide the personal data required for the conclusion, execution, and administration of the agreement with the Partner, the processes may be disproportionately complicated, delayed, or impossible.
5.3. Purposes of Personal Data Processing.
We process your personal data for the following purposes:
for the conclusion and proper administration, accounting, and implementation of agreements with the Partner, based on the personal data provided in point 5.1, depending on the specific situation;
for direct marketing purposes (email) - only if you have given us your explicit consent.
5.4. Legal Basis for Personal Data Processing.
Your personal data for the conclusion and proper administration, accounting, and implementation of agreements with the Partner are processed based on our and/or the Partner's legitimate interests, which include the aim to conclude and/or execute the agreement with the Partner, resolve issues arising during the performance of the agreement, etc. Your personal data contained in documents confirming economic operations are also processed on the basis that it is necessary to process this data in order to comply with the legal obligation imposed on the data controller - to comply with the rules of invoicing and other payment formalization and accounting rules; Your personal data for direct marketing purposes are processed based on your consent given to us - please note that you have the right to withdraw your consent at any time (you can do this by clicking on the appropriate link in each received electronic message or by submitting a request to us by email or by other means in accordance with the procedure set out in Section X of this Privacy Policy).
5.5. Retention Period for Your Personal Data.
Your personal data for the conclusion and proper administration, accounting, and implementation of agreements with the Partner are processed during our contractual relationship with the Partner, except for personal data contained in documents confirming economic operations, which are stored for 10 years for accounting purposes; Your personal data for direct marketing purposes are processed for 1 year from the receipt of your consent. Information proving your consent to data processing is stored for 2 years after the withdrawal of consent or the expiration of its validity. After the retention period for your personal data has expired, we securely destroy your personal data.
VI. Security
CityFun protects data using the capabilities of modern technology, taking into account the existing privacy risks and CityFun's available organizational, financial, and technical resources, including the following security measures: firewall; intrusion detection and prevention programs; and other security measures, taking into account the possibilities associated with the development of current technologies. We will take all necessary technical and administrative security measures to protect your Data from unauthorized loss, access, and unauthorized alteration, disclosure, or deletion. CityFun does not intend to transfer your personal data outside the European Economic Area or to an international organization. However, in the event that our data processors process your personal data outside the European Economic Area (e.g., if servers of service providers are located outside the EEA), we will take all appropriate and adequate measures to ensure the security of your data as required by the relevant laws and regulations on personal data protection. Geographical data is processed anonymously and is only individualized if geographical location data is necessary to resolve a specific situation or fraudulent payments; Data is used anonymously for research and scientific purposes;
VII. Recipients of Your Personal Data
Certain personal data may be disclosed to our authorized data processors, such as IT or cloud service providers (e.g., if we rent servers from an IT company, your personal data will be physically stored with the mentioned IT company), and other technical implementers of CityFun games. Please be informed that we require our data processors to ensure appropriate protection of your data and we ensure that your personal data will only be processed by data processors to the extent we require them and for the purposes specified. If you have questions about our service providers, please contact us at the following email address: info@cityfun.lt. In certain cases, we may disclose your information to other entities, other than described above: in order to comply with applicable legal requirements or receive a mandatory court order (e.g., upon receipt of a court injunction to provide data), to protect our legal interests, to protect our rights, property or security, with your consent, or at your legitimate request.
VIII. How we process your personal data
We process your personal data in accordance with applicable legal requirements, including, but not limited to: Your personal data will be processed in accordance with the principles of lawfulness, fairness, and transparency; Your personal data will be used only to the extent necessary to achieve the specified purposes; Your personal data will be collected only for legitimate purposes that we have clearly communicated to you and will not be used in any other way incompatible with those purposes; Your personal data will be accurate and regularly updated; Your personal data will be stored only for as long as necessary to achieve the purposes for which they were disclosed to us (or as required by applicable laws); Your personal data will be used to ensure an adequate level of security.
IX. Your rights related to your personal data
In accordance with the data protection regulations, you have the following rights: You have the right to be informed whether we process your personal data and, if so, to access copies of the processed data, as well as information about how we use your data, with whom we share it, and how long we retain it. We may refuse to provide you with information or request you to cover the cost of making additional copies when you request the same information again; You have the right to request correction, supplementation, or amendment of inaccurate, incomplete, or outdated personal data (right to rectification) - in case you determine, after reviewing your personal data, that the data is inaccurate, incomplete, or misleading. You have the right to request that we delete the available information about you if it is processed unlawfully or unfairly, is no longer necessary for the purpose for which we collected it, and there is no other legal basis for us to retain such information; You have the right to request that we restrict (suspend) the processing of your personal data, except for storage - in case, for example, you have submitted a request to correct personal data (while the accuracy of personal data is being verified and/or corrected), it is determined that personal data is being processed unlawfully and you do not consent to the data being deleted, or you have expressed objection to the processing of personal data (while assessing whether our legitimate interests prevail) and so on (right to restrict the processing of personal data); You have the right to receive from us and transmit to another data controller your personal data in a structured, commonly used, and machine-readable format (or request us to do so), if the processing of your personal data is based on your consent or the performance of a contract, and is carried out by automated means (right to data portability); You have the right to object to the processing of your personal data, including profiling based on automated processing, and to request that we stop such processing (right to object to processing).
X. Presentation of a Request for Implementation of Data Subject Rights
To exercise your rights regarding the implementation of data subject rights, you have the right to submit a written request to us in person, by mail, or by email. If you submit the request in writing in person, you must confirm your identity by providing a document confirming your identity. Failure to do so will result in the data subject rights not being implemented. If a request for implementation of data subject rights is submitted by mail, a copy of a notarized document confirming the person's identity must be submitted along with the request. When submitting a request electronically, the request must be signed with a qualified electronic signature, or it must be formed using electronic means that ensure the integrity and non-repudiation of the text (this requirement does not apply if you wish to withdraw your consent for direct marketing messages or newsletters). The request to implement data subject rights must be clear, signed by the person, and must specify the data subject's name, surname, address, and/or other contact details for communication or for receiving a response regarding the implementation of data subject rights. A data subject can exercise their rights themselves or through a representative. The representative must provide their name, surname, address, and/or other contact details for communication, as well as the name and surname of the represented person, and provide a document or a copy of a document confirming the representation. If there are doubts about the identity of the data subject, we may request additional information to verify it. Upon receiving your request, no later than one month from the receipt of the request, we will provide you with information about the actions taken based on the received request.
XI. Regarding the Personal Data of Children
CityFun games cannot be directly purchased or created by individuals under the age of 14. If you are under the age of 14, please do not provide us with any of your personal data. If you are the parent/legal guardian of a child under the age of 14 and you become aware that your child has provided us with their personal data without your written consent, please contact us so that we can delete your child's personal data.
XII. Changes to the policy and our contact information
MB Enjoy events has the right to partially or fully change the privacy policy by notifying it on its website. Further use of our services implies compliance with these rules. All disputes and disagreements are resolved through negotiations. In case of failure to reach an agreement, disputes are resolved in accordance with the laws of the Republic of Lithuania. The terms used in the privacy policy are understood as defined in the General Data Protection Regulation No. 2016/679 (EU).
MB Enjoy events, Email: info@cityfun.lt CityFun contact information for reporting possible data breaches: info@cityfun.lt
