Last Updated and Effective Date – 28.11.2024

1. General information
The protection and legally compliant collection, processing and use of your data is an important matter to us so that your privacy is respected. This Privacy Policy sets out key information regarding your rights and explains what data and how we collect and process when you use our Services.
In this Privacy Policy we use the following references:

• “We”, “our”, “us” refer to “Scorela Limited”. You may find our contact details in the section below.
• We may refer to you, the person or entity using our Services, as “you” or “your” or our “Customer”.
• “Website” – https://synthigames.com/.
• “Services” – all and any services which can be offered by us to you via our Website and Apps  based on our Terms of Service. The scope of the Services available and offered may change from time to time given the possible developments and upgrades made by us.

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services as well to the situations when we act as a data processor on your behalf. It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data. If you do not agree to your data being used in the manner described in this Privacy Policy, please do not use our Services.

2. Name and Address of the Controller
We are the data controller for your personal data that are processed in connection with the use of the Services.  Here you may find our contact details:

If you have any requests regarding your personal data or any questions regarding this Privacy Policy or if you would like to have more information about how we collect, use and store your personal data you can contact us at any time.

3. Personal data we collect

3.1.Technical data when you use our Services

Whenever you use our Services, the following technical data will be automatically collected and stored: information on your browser type and version, the operating system and platform you are using, the website from which you are visiting us (if available), your IP address, date and time of your visit. We collect this personal data by using cookies, server logs and other similar technologies.

3.2. When you register for an account

Some of our Services due to the nature and scope of services may require you to create an account or may offer additional services or functionalities when you use our Services via registered account. Moreover, if you create an account, you will not have to send us your personal data every time you are using our services or have the intention to use them. At the same time, you may enjoy some Services even without the need to register for an account.

To register an account you have to provide us with an email address, create a password and username and provide other information requested by our Services. The personal data will be processed for creating and maintaining your account and providing access to the Services and a better user experience.

As an alternative, instead of the creation of a separate account, in some cases you may choose to sign up with your social media accounts (Google Account or Github Account). If you choose to register or log in to our Services using social media accounts, we may have access to certain information about you from your social media provider. Information we receive may vary depending on the social media provider concerned and their privacy policies but often include name, email address, language settings as well as other information you choose to make public. We will use the information we receive only for the purposes that are described in this Privacy Policy. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider.

If we are asking for optional information, we will inform you about why we are collecting such information.

You can delete your account and any data stored therein at any time. To do so, please send us an informal notice (e.g. via e-mail).

3.3.When you contact us

We collect the communication data that accrues when you contact us via email or other means to request technical or customer support or for other reasons. Depending on the channel you use, this may comprise for example your contact details (e.g. your email address or phone number), the contents of your message as well as any other relevant information contained in the body of your communication. The data you provide when contacting us will be transmitted to and used by, us to deal with your query.

3.4.When you sign up for the newsletters

If you decide to sign up for our newsletter (if any), we will process the email address that you have provided to this end to compile and mail the newsletters. In the future, you can opt out of receiving newsletters at any time at your discretion by contacting us.

3.5.When you provide feedback on our products and services or participate

If you decide to leave feedback on/to rate our products and services on the Website (for instance, to leave a review to Services purchased), we and other users may find your login, rate as well feedback placed by you.

3.6. Cookies

We use cookies. Such cookies may be our own cookies (so-called “first-party cookies”) or third-party cookies. A cookie is a standardized text file that is kept on your computer or other devices by your browser or app for a period of time as predefined by the respective provider. Cookies we use can be “persistent” cookies (stored on your device in between browser sessions) or “session” cookies (stored during a browser session, expire each time after the closure of the browser and do not remain on your device afterwards). We may use the following cookies:

• Essential cookies. These cookies are required for the operation of our Services. They make our Services usable.
• Functionality cookies. These cookies are used to recognize you when you return to our Services, to personalise our content for you and remember your preferences (for example, your choice of region or language).
• Analytical and performance cookies. They allow us to measure our audience, traffic sources, recognize and count the number of visitors and see how visitors use our Services. This helps us to improve the way our Services works.
• Targeting cookies. These cookies may be set through our Services, in particular, by our advertising partners. These cookies may be used to show you relevant adverts.

Our own cookies are meant to make your usage of our Services more user-friendly and safer. We may use third-party cookies for analytical and advertising purposes.
You can review and delete the cookies used in the security settings of the browser you use. You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or any cookies. Please note if cookies are not accepted, the functionality of our Services may be limited.

4. How we use data we collect and receive

We may rely on different lawful grounds when processing personal data, in particular:

• Where we have to fulfil our contractual obligations
• Where we have a legal obligation
• Where we have your consent
• Where we have a legitimate interest

If and insofar we rely on legitimate interests we proportionate any possible impact on you and your rights before we start processing your personal data relying on our legitimate interests. We do not use your personal data in cases where our interests begin to prevail over the impact that they may have on you (except in cases where we have your consent, or when this is required or permitted by law or related to the fulfilment of the contract with you). We may use your personal data for the following purposes and on the following legal grounds:

4.1. Provisions of Services and contract performance

We process your data to render the Services you have requested under our Terms of Service. The specific purposes and type of data are based primarily on the type of Services you have requested from us under our Terms of Service. This includes:

• To create your account and provide access to it;
• To allow you to order Services, to fulfil and manage your orders, including recording your order details and keeping you informed about the order status;
• To provide access to Services and render Services with necessary functionalities;

The legal basis for this type of data processing is Article 6 para. 1 lit. b GDPR (performance of a contract and taking of steps prior to entering into a contract).

4.2. Customer service and communication under existing customer relationships

We will process your data as part of our Services. This will include for example processing of your concerns and requests by our customer service as well as non-promotional communication with you (e.g. safety information and technical support).
The legal basis for this type of data processing is Article 6 para. 1 lit. b GDPR (performance of a contract and taking of steps prior to entering into a contract).

4.3. Payment processing

Some of our Services are subject to payment which means that when you decide to purchase our Services processing of your data will be needed to finalize purchasing processing and to carry out the payment. Depending on the payment method used, the data necessary for payment processing (e.g. direct debit or credit card data) will be processed and passed on to the respective payment service provider. We also may process your transactional and payment data and details to consider the refund request from you (where applicable).
The processing and transmission of your data to external payment service providers are based on Article 6 para. 1 lit. b GDPR (contract performance).

4.4. Promotional communication

We may send you marketing communications where we have a commercial relationship with you (e.g. you use our Services) to recommend services, discounts or provide you with the special offering that may be of interest to you via account or via the e-mail address unless you have objected to receiving such communications from us. You can object to such kind of communication at any time.
Normally, the legal basis for this type of data processing is Article 6 para. 1 lit. f GDPR (weighing of interests based on our above-mentioned legitimate interests). In cases we believe such marketing communication could not be based on our legitimate interests due to specific circumstances then we will ask for your consent.

4.5. Internal market research, optimization, and enhancement of our offer

We may use aggregated, non-personally-identifying information such as technical data and usage data for research purposes and to operate, analyze, improve, and optimize our Website and Services.
That way we can learn, for example, which of our Website pages and Services are particularly popular, which devices our customers use in general, and which regions our Website is accessed from. This information helps us to continuously optimize our existing offer and to develop new functions and services as well as to keep our Website updated and relevant.
The legal basis for this type of data processing is Article 6 para. 1 lit. f GDPR (weighing of interests based on our above-mentioned legitimate interests).

4.6. Complying with legal obligations

We may process your relevant personal data in cases and to the extent, we are required to do so by applicable legislation to comply with our legal obligations. The legal basis for this type of data processing is Article 6 para. 1 lit. c GDPR (legal obligation).

4.7. Protecting our interests

We may also process your relevant personal data when it is needed for security purposes or to maintain ongoing confidentiality, integrity, availability, and resilience of our systems, Website and Services or to protect, investigate, deter and report the fraudulent, unauthorized or illegal activity as well as to protect our intellectual property and other rights and interest or enforce our Terms of Service.
The legal basis for this type of data processing is Article 6 para. 1 lit. f GDPR (weighing of interests based on our above-mentioned legitimate interests).

5. How we share information with others

We do not rent or sell your personal data to anyone.
To achieve the purposes set out in the Privacy Policy we may share information with suppliers, contractors and other third parties (collectively – service providers) who help us provide and improve the Website/Services we provide to you, in particular payment processing providers or external IT service providers. We also may share your personal data with our professional advisers including lawyers and auditors who provide consultancy, legal and accounting services.
All service providers to whom we may provide your personal data receive the minimum amount of personal data that is reasonably necessary for them to provide services to us and, accordingly, to you.
All service providers to whom we may provide personal data must protect personal data under corresponding applicable laws and regulations.
We do not share your personal data with service providers that we believe are unable to provide the appropriate level of data protection.
If and insofar as your data is shared to service providers located outside the European Economic Area (EEA), we will consider data transfer rules and rely on adequacy decisions or apply appropriate and valid safeguards such as standard contractual clauses. You may contact us for more information about appropriate safeguards for international data transfer.
We may provide your personal data when required by law and/or regulatory authority requirements.
We also may also reveal your personal data to third parties if you request or authorize it or to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.
We may share personal data if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of personal data and in the manner allowed by the legislation.

6. Storage of personal data

We retain personal data for only as long as we need it to comply with our legal obligations, provide the Services you requested and perform contractual obligations as well to achieve other purposes described in this Privacy Policy and for any periods that are mandated by applicable law, after which, we take steps to delete or anonymize information.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data involved, the potential risk of harm from unauthorised use or disclosure of your personal data, as well the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you decide to delete your account, all personal data stored therein will be deleted. Please note that deletion of your account does not automatically extend to the order processes and the personal data stored for this purpose as well as our obligations imposed by the applicable legislation.
If and insofar as your data cannot or does not have to be deleted completely for legal reasons, the data concerned will be restricted for further processing. Normally, your order and payment data and other data, if applicable, will be subject to statutory retention obligations, for example under tax regulation.
Even if your data is not subject to statutory retention obligations, we may refrain from deleting your data in cases permitted by law and restrict its processing instead. This may apply, in particular, in those cases where the data concerned may be required for further contract processing or to assert rights or for legal defence purposes. The duration of the restriction of processing will depend on the statutory limitation periods.

7. Security

We define and implement the reasonable technical and organizational measures necessary to maintain the security of personal data, according to the nature of the personal data processed and the circumstances of the processing, to avoid non-authorised processing or access, alteration or loss of personal data. These measures will be adjusted from time to time in line with the state of the art.

8. Third-Party Links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies.
We recommend you read the privacy statements of all third-party sites before using such sites or providing any personal data or any other information to or through these sites.

9. Your rights under the GDPR

The European Union’s General Data Protection Regulation (“GDPR”) provide you as a data subject with certain rights that you may exercise.

Right of access

You have the right to demand at any time access to your personal data that are processed by us as well as information about the processing of your personal data. When providing such information, we will explain our data processing process, provide you with an overview of the personal data we store and fulfil other obligations imposed on us by the applicable law.

Right to rectification

You have the right to demand prompt rectification and/or completion of your personal data if the personal data are inaccurate or incomplete.
Right to withdraw a given consent
You have the right at any time to stop a data processing that is based on your consent by withdrawing a given consent. The withdrawal will not affect the lawfulness of the processing based on the consent before the withdrawal.

Right to erasure and/or restriction of processing

You have the right to demand the erasure of your personal data. If you ask us to, we have the obligation to erase the data without undue delay. The foregoing does not apply, however, if any contractual and/or legal provisions require us to continue processing your personal data. This may be the case, for example, when retention periods under tax law prohibit us from erasing the data. In such a case, we will restrict the processing and erase the personal data immediately after the expiry of the retention period.
You can also restrict the processing of your data, e.g. if you think that the data stored by us is not accurate. Please note, when you make a request, we may still store your information and use it for legal claims purposes or if it is necessary to protect another person.

Right to object

You have the right to ask us to stop using your information where our processing is carried out for “legitimate interests” and you have grounds relating to your personal situation which requires us to stop using your information or where we have collected your information for direct marketing and you want us to stop using it for direct marketing purposes.

Right to data portability 

You have the right to receive your personal data provided to us in a structured, commonly used and machine-readable format wherever this is technically possible. In addition, you have the right to transmit these data to another controller without hindrance, if you wish to do so.

Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling, which produces legal effects concerning you or significantly affects you in a similar way. Please note, as part of the processing, there will not be any automated decision-making that produces legal effects concerning you or similarly significantly affects you.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of the personal data relating to you infringes the general data protection regulation. In general, you may address the supervisory authority of your habitual residence, place of work or our domicile.

10. How to exercise your rights?

You may exercise your rights by contacting us as provided in section 2.
We may require to receive proof of your identity before we can respond to your request.
Please note that we may refuse, restrict or defer the exercise of the rights where we have the right to do so under the applicable data protection legislation.

11. Changes and updates of our Privacy Policy

We may change this Privacy Policy from time to time and publish updated versions, together with notices of changes where appropriate and also encourage you to review this Privacy Policy periodically.
If we are going to use personal data in a manner materially different from that stated at the time of collection and/or material changes are planned to be introduced, then we will notify you via email or account or by posting a notice on the Website in advance so you will have time to familiarize yourself with changes planned for implementation and will take other steps if necessary under the applicable law.