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数据传输协议

DATA TRANSFER ADDENDUM FOR SNAKZY SERVICES

 

Version 1.0, last amended 2024-07-29

  1. Scope of DTA
    1. This Data Transfer Addendum for Snakzy Services (“DTA”) to the Snakzy Advertising Terms and Conditions is applicable only to the extent Client exports to or receives from Snakzy personal data that is defined as “personal data” under applicable EU Data Protection Law (defined below). Capitalized terms used in this DTA shall have the meaning given to them in the main body of the Snakzy Advertising Terms and Conditions unless otherwise defined in this DTA.
  2. Definitions
    1. controller, processor, data subject, personal data, personal data breach, and processing (and process) have the meanings given in applicable EU Data Protection Law.
    2. EU Data Protection Law - mean as applicable to a party in its Processing of Data: (i) Regulation 2016/679 (the European General Data Protection Regulation (“GDPR”); (ii) the EU e-Privacy Directive (Directive 2002/58/EC) (“e-Privacy Directive”); (iii) all national implementations of (i) and (ii); (iv) the Swiss Federal Data Protection Act of 19 June 1992 and its corresponding ordinances (“Swiss DPA“); and (v) in respect of the United Kingdom, GDPR as it forms part of United Kingdom law pursuant to Section 3 of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018 the (together, “UK Privacy Law“); in each case, as may be amended, superseded or replaced from time to time.
    3. GDPR - the EU General Data Protection Regulation 2016/679, as amended or updated.‍
    4. Restricted Transfer - a transfer of Personal Data from the European Economic Area to a country outside of the European Economic Area which is not subject to an adequacy determination by the European Commission.
    5. Standard Contractual Clauses or SCCs - contractual clauses annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 located at https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021D0914.  
  3. DTA General Terms
    1. Applicability of this DTA. The DTA shall be applicable to all data transfers conducted during provision of Snakzy Services in conjunction with Section 7 of the Snakzy Advertising Terms and Conditions. In the event of any conflict or discrepancy of Snakzy Advertising Terms and Conditions and this DTA, the terms of this DTA shall prevail.
    2. Roles of the Parties. Both Parties confirm and agree that they are independent controllers of the personal data transferred under this DTA.
    3. Compliance with EU Data Protection Laws. Each Party shall be responsible for compliance with the requirements of EU Data Protection Laws and other applicable data protection and/or privacy legislation in their capacity as independent controllers, including, but not limited to: i) requirements to provide sufficient notification(s) to the data subjects about the transfer of their personal data under this DTA, ii) where necessary, requirement to collect data subject’s informed consent to the processing.
    4. Onward Restricted Transfers by Snakzy. In cases where Snakzy performs any further transfers of personal data received from the Client to third parties, Snakzy shall ensure that such data transfer is subject to one of the safeguards established by Articles 45-49 of GDPR, including, but not limited to conclusion of SCCs (Module 1 for controller to controller transfers, Module 2 for controller to processor transfers).
    5. Further processing of personal data. As independent controller of personal data transferred under this DTA, Snakzy shall have the right to decide further processing purposes of personal data transferred under this DTA without any authorization or approval by the Client, provided that Snakzy complies with applicable EU Data Protection Laws and other applicable data protection and/or privacy legislation.
  4. Changes to this DTA
    1. Snakzy may update the terms of this DTA from time to time, as may be required to comply with EU Data Protection Law, applicable regulation, court order, or regulatory guidance. If Client objects to any such change, Client may terminate the Agreement by giving thirty (30) days prior written notice to Snakzy.
  5. ‍Acceptance of this DTA
    1. By executing an Order or Insertion Order incorporating the DTA via Snakzy Advertising Terms and Conditions, or by using the Snakzy Services in the absence of a signed Insertion Order, Snakzy and Client has agreed to the terms of this DTA, effective as of the same date of the Insertion Order or the start of the Services, whichever is earlier.

ANNEX A- Description of the Transfer

  1. LIST OF PARTIES

Data exporter(s): Client, as indicated in the applicable Insertion Order

Address: 

  • As indicated in the applicable Insertion Order

Contact person’s name, position and contact details:  As indicated in the applicable Insertion Order

  • Activities relevant to the data transferred under the DTA: collection of Client’s application’s End Users’ personal data required for Snakzy to provide Services

Date:

  • As indicated in the applicable Insertion Order                                                                                                                                            

Signature:

  • As indicated in the applicable Insertion Order

Role (controller/processor):

  • Controller 

‍Data importer(s): Snakzy (UAB Helis play)

Address: 

  • Gyneju st. 4-333, LT-01109 Vilnius, Lithuania

Contact details: 

Activities relevant to the data transferred under the DTA: 

  • Data importer’s measurement and rewarding of end users with rewards, which can be redeemed for various digital goods (determined by the data importer), as end users install and engage with data exporter’s applications

Date: 

  • As indicated in the applicable Insertion Order

Signature:

  • As indicated in the applicable Insertion Order

Role (controller)/processor):

  • Controller

‍DESCRIPTION OF TRANSFER

Categories of data subjects whose personal data is transferred

  • End users of Client’s Application who view ads, in-app content, play games or otherwise interact with Client’s Application.

Categories of personal data transferred

  • Client’s End Users data, including but not limited advertising identifiers, device identifiers, location data, and IP addresses, other personal data provided to Snakzy during provision of Services
  • Application’s in-app events
  • Application’s game play, in-app purchases, and device data, including device identifiers
  • Analytical Application usage data 

Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.

  • Sensitive data is not transferred.

The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis).

  • Transferred continuously throughout the provision of Snakzy Services.

Nature of the processing

  • Storing and analyzing data to provide Snakzy Services.  

Purpose(s) of the data transfer and further processing

  • For game players, the data is transferred to personalize advertising and in game purchase opportunities as well as to personalize game play.
  • To facilitate the development of Snakzy proprietary products, services and software, including, but not limited to development and training of machine learning and AI algorithms
  • To operate Snakzy Platform, ensure its continuous operation and provide a satisfying experience to End Users.
  • To enable Client to advertise its products, services, or promotions to End Users via Snakzy Services.
  • To provide analytics reporting.
  • For Snakzy’s business purposes, including billing and payment processing, fraud prevention, and improving products and services.
  • Other purposes, as indicated in Snakzy Advertising Terms and Conditions, Terms of Use, Privacy Notice or other documentation

Retention period. The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

Snakzy retains personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time Snakzy has an ongoing relationship with the data subject and/or Client, including the provision of Services;
  • Whether there is a legal obligation to which Snakzy is subject;
  • Whether retention is advisable in light of our legal position.