Privacy Policy
We, at SEVEN MAGES, a team of game designers based in Zoetermeer, The Netherlands (“Seven Mages” or “we”), have developed the Penguin Panic App (“Penguin Panic App” or “App”), a digital product created to children, their carers, and also professors, with videos, games, and books selected by experts, and which may be accessed by a variety of media, such as websites (www.jeroenderwort.nl) and also in apps in several platforms.
This Privacy Policy describes the form how Penguin Panic uses the data that may be directly or indirectly collected from the Penguin Panic App users.
The acceptance of this Privacy Policy (“Policy”) will occur when the user or, when necessary, the respective father, mother, or tutor accesses the App and agrees with the use of his or her personal data to each purpose described herein. In case you do not agree with this Policy, please, do not continue interacting with the App. However, we would like to know the reason of your disagreement so that we can improve our products. Please contact us at privacy@derwort.nl.
Seven Mages takes it very seriously when it comes to the personal data of the App users. Due to this reason, no personal data of users will be collected, stored, or otherwise processed for any purpose other than those expressed herein, except in case of a legal obligation to be observed by Seven Mages. Therefore, Seven Mages will disclose in this document the technical and organization measured employed to warrant the protection of the personal data of the App users.
What are Personal Data?
Personal Data are all information that may identify or make identifiable any person (“Personal Data”), such as, for instance, name, IP address, and residential address.
What will Seven Mages do to your Personal Data?
When using the App, users may voluntarily provide their Personal Data, when making a purchase in the app, for instance. In addition, users may have their Personal Data collected indirectly by tools that mange statistical analyses on the App usability, such as information on error, quantity of users online, and most used features.
Safeguarding the transparency and privacy of its users, the purposes to which Seven Mages processes the Personal Data, the Personal Data used, and the respective legal bases that justify their use:
| Purpose | Personal Data | Legal Base |
| Access log |
IP address and geolocation |
Observance of legal obligation and Legitimate Interest |
| Registration and login |
E-mail, name, address, CPF, year of birth, telephone, Facebook ID, Apple ID, Google ID (Ids are the user accounts in the respective platforms, which may be used to login into the App) of the father, mother, or tutor |
Consent |
| Subscription retrieval by partner operator |
Operator and mobile number |
Contractual performance or performance of preliminary procedures of the contract |
| Payment |
Name, CPF, address, card data (card name, card number, security code and date of expiry) and country |
Contractual performance or performance of preliminary procedures of the contract |
| Update of registration of father, mother, or tutor |
Name, CPF and password |
Contractual performance or performance of preliminary procedures of the contract, and observance of legal or regulatory obligation |
| Update of child registration | Child nickname, date of birth | Consent and Observance of legal or regulatory obligation |
| Delivery of essential or requested communications |
Name, e-mail and token to send push notifications. |
Contractual performance |
| Analytics and Marketing |
Advertising_id (unique user ID generated by the analytics platforms and digital advertising) and profile of interests |
Consent and Legitimate Interest (the latter for data anonymization) |
| Support |
E-mail and other information sent by the user during the service, for instance, name, telephone, CPF and card data (card name, card number, security code, and date of expiry). |
Legitimate Interest |
| Customization of the cart contents |
Child nickname, date of birth, and favorite themes. |
Consent |
Seven Mages undertakes to collect and process the Personal Data of children and teenagers according to the applicable legislation, which shall occur with the specific content of the respective father, mother, or tutor, for the uses and purposes set forth in this Policy.
Nonetheless, in case the user is willing to obtain more detailed information about the processed commented above, contact Seven Mages using our contact channel, at privacy@derwort.nl. Seven Mages will work diligently to answer your inquiry, provided it does not conflict with the intellectual property rights of Seven Mages, including trade secrets.
With whom Seven Mages may share Personal Data?
Seven Mages may operate in conjunction with other companies in several activities, including for the hosting of Personal Data, Analytics, and delivery of communications. Whenever possible, we will adopt mechanisms to anonymize these Personal Data, aiming at preserving your privacy at the most. Therefore, we reserve the right to share the Personal Data exclusively with the companies listed below:
Suppliers: we contract other companies to act on our behalf, and we need to share your Personal Data with such companies to provide the Penguin Panic App. For example, we use Data hosting services to store our data base and share your information with technology providers. Our suppliers are only authorized to use the Personal Data for the specific purposes contracted, therefore they will not use your Personal Data for any purpose other than the services contractually agreed.
Seven Mages Partners: Seven Mages may establish partnerships to provide its services and, for such, it may share Personal Data of users with the partners listed in the link below to establish the offer of products and services.
Analytics: The Personal Data stored by Seven Mages may be used for statistical purposes (Analytics), so that Seven Mages understands how users interact with the App. Such Personal Data are pseudonymized and do not identify or make identifiable the holders of Personal Data, having the exclusive purpose of understanding in depth how the App is used, so that the products and services offered are improved and tailored to the user.
Marketing and delivery of communications: Seven Mages contracts marketing companies to send its communications and to direct content and ads according to the user interests. For such, certain Personal Data may be shared by Seven Mages and such companies, mainly identified as unique, IP addresses, cookies, behavioral data, and data on the consumption history, which may be used to measure the efficiency of the online advertising. The user may opt for receiving such ad, with the express consent on the App, which may be canceled at any time, against request via e-mail privacy@sevenmages.nl.
The agencies and companies contracted by Seven Mages for these purposes are committed to the same protective and privacy level adopted by us; this includes the obligation of not using your Personal Data for any purpose other than the contracted purpose, in addition to obligations of confidentiality and security standards, among others. We use our commercially reasonable efforts to assure that our third-party service providers have their Personal data protected and safe.
To safeguard and protect the rights of Seven Mages: Seven Mages reserves the right to access, read, preserve, and disclose any Personal Data it believes to be necessary to comply with a legal obligation or court order; comply with this Policy, the Terms of Use and other agreements; or protect the rights, property, or security of Seven Mages, its employees, users, or others.
Affiliated Companies: Seven Mages may transfer the Personal Data to affiliated companies in order to improve its services and products, according to the list of affiliates presented below. All companies are subject to contractual obligations under which they undertake to process the Personal data of users with the same degree of security and according to the applicable legislation.
Seven Mages uses its best efforts and acts in good-faith to protect and assure the privacy of your Personal Data. When we share your Personal Data with any of the companies indicated above, we restrict the sharing exclusively to Personal Data necessary for the conduction of the respective tasks, and we assure in contract that such Personal Data is only used to the extent necessary for the provision of the services on our behalf or for the observance of the legal requirements. Similarly, we require such third parties to adopt the same degree of protection and privacy to their Personal Data that Seven Mages would have if processing such data directly; this includes the obligation of not using your Personal Data for any purpose other than the contracted purpose, in addition to obligations of confidentiality and standards of information security, among others. In addition, we always use our commercially reasonable efforts to assure that our third-party service providers have their Personal data protected and safe.
Does Seven Mages perform any international transfer of Personal Data?
Yes. Although Seven Mages is headquartered in The Netherlands and its products and services are destined to individuals in The Netherlands, therefore subject to the Dutch laws related to the protection of Personal Data, the Personal Data collected may be transferred to the United States of America. This transfer occurs mainly for the purposes of cloud hosting at the Seven Mages servers.
Please read carefully the privacy policy of suppliers and commercial partners, which may identify the exact location of their headquarters and servers.
When providing Personal Data to Seven Mages, the user, his or her father, mother, or tutor, agrees with the processing and international transfer of such Personal Data to the United States of America. These Personal Data may be subject to the local legislation and the pertinent rules.
What are the rights of users as holders of Personal Data?
The user may always opt for not disclosing Personal Data to Seven Mages, however such Personal Data may be necessary so that the user may enjoy certain features of the Penguin Panic App. Notwithstanding the foregoing, the user will always have rights related to the privacy and protection of your Personal Data. Seven Mages is concerned with the security of such Personal Data and that its users have access and know all rights related to the processing of their Personal Data.
In this regard, we expose below a brief explanation and some examples about these rights:
- Request for confirmation of the existence of processing: This right allows the user to request and receive a confirmation about the existence of processing of their Personal Data.
- Request for access to Personal Data: Such right allows the user to request and receive a copy of the Personal Data processed by Seven Mages. To help your privacy and security, we will adopt reasonable measures to verify your identity, such as, for instance, the use of password and user identification before granting access to your Personal Data.
- Request for correction of incomplete, inaccurate, or out-of-date data: This right allows the user, at any time, to request the correction and/or rectification of Personal Data, in case any incorrect data is identified. However, in order to perform this correction, Seven Mages will need to check the validity of the Personal Data provided.
- Request for anonymization, freeze, or elimination of data deemed unnecessary, excessive, or processed not in accordance with the legislation: Such right allows the request for anonymization, freeze, or elimination of the Personal Data from the data base of Seven Mages. All Personal Data collected will be anonymized, blocked, or eliminated from the servers as soon as requested or when no longer necessary or relevant for the provision of the services, except in case of any other reason for their maintenance, such as the eventual need to hold Personal Data for the observance of a legal obligation to protect the rights of Seven Mages.
- Request portability: Seven Mages allows the user or third parties indicated thereby to access the Personal Data processed by Seven Mages in structured, inter-operable format.
- Right not to supply or to revoke the consent at any time: The user has the right not to supply or revoke his or her consent, however, such fact will not affect the legality of any processing previously occurred. If the user does not supply or revokes its consent, perhaps Seven Mages may not be able to provide certain products and services. And, if the case, Seven Mages will inform the user whenever it occurs.
- Right to review automated decisions: The user is also entitled to request the review of decisions made solely based on the automated processing of Personal Data affecting the interests of users.
- Right to contest specific Personal Data processing: The user is also entitled to contest specific processing purposes. In some cases, Seven Mages may demonstrate it has legitimate reasons to process Data, which may overlap the rights of users, if, for instance, they are strictly essential for the functionality of the products or services.
It may be necessary to request specific user information, or information of the father, mother, or tutor, to confirm identity and assure the right to access your Personal Data (or to exercise your other rights). This is a security measure to assure that the Data are not disclosed to any person not entitled to receive them.
Seven Mages will make its best efforts to reply all legitimate requests within five (5) business days for requests of rectification and fifteen (15) business days for the other requests. Occasionally, the reply may take more than fifteen (15) business days if the request is particularly complex or if the user has made various requests. In this case, we will communicate the holder of the information and keep him or her up-to-date of the request.
If you have any doubts about these issues and about how the user may exercise such rights, Seven Mages undertakes to solve them in the following contact channel: privacy@derwort.nl.
For how long are the Personal Data of users stored?
Seven Mages will keep the Personal Data of users only for the time necessary to comply with the purposes to which they are collected, including for the purposes of observance of any legal obligations (such as the safeguard of access logs to the application for 6 months, according to the Internet Civil Framework), contractual obligations, obligations to render account, or request by competent authorities.
In order to determine the proper retention period of the Personal Data, Seven Mages takes into account the quantity, nature, and sensitivity of such Data, the potential risk of damages resulting from the unauthorized use or disclosure of Personal Data, the purpose of processing, and if the respective purpose may be achieved by other means, as well as the legal requirements applicable.
Nonetheless, if you signed with an account on the Seven Mages App, the information of your account will be maintained as long as you keep this account active. Your account and the information related to it will be excluded if you do not login for five (5) years. You may also request the exclusion of your Data and/or your account, case in which Seven Mages will keep the Data for fifteen (15) days from the request of exclusion.
It is worthwhile noting that Seven Mages may retain the Personal Data for a period longer than the indicated above to meet any legal obligations eventually applicable, under the terms set forth by the pertinent legislation, such as the consumer defense and tax rules.
How does Seven Mages protect user Data?
Seven Mages adopts technical, administrative, and organization measures to protect the Personal Data of users against loss, unauthorized use, or other abuses. The Personal Data are stored in a secure operating environment not accessible to the public.
Seven Mages makes its best efforts to protect the privacy of the account and the Personal Data of the users in its data base. We adopt measures of procedural, technical, and physical nature to help us preventing the loss, undue use or unauthorized access, disclosure, change, or destruction of the Personal Data supplied by the users. However, there is no guarantee that a transmission of Personal Data via Internet is completely secure. It is possible that third parties not under our control intercept or gain access to the transmissions or Personal Data by illegal means. Therefore, in case of impossibility of assurance of the complete security of the Personal Data transmitted to our website, we ask your cooperation to help us maintain a secure environment to all. If you identify or become aware of anything that may compromise the information security, please contact Seven Mages using our proper contact channel privacy@derwort.nl.
How do I contact Seven Mages?
If the user believes that his or her Personal Data were used in any manner not compatible with this Privacy Policy or his or her respective choices as holder of such Personal Data, or in case of any doubts, comments, or suggestions, related to this Policy, the user may contact Seven Mages team in the following media:
Seven Mages Customer Support Center
Telephone: 4000 1718 (mobile only)
Telephone: 0800 944 1718 (fixed lines only)
E-mail: suporte@derwort.nl
Changes to the Privacy Policy
Since Seven Mages is always seeking to improve its services, this Privacy Policy may be subject to updates. Thus, we recommend the user to periodically check this page in order to keep the most up-to-date content. In case of relevant changes that need a new user consent, we will publish such update and request a new consent.
Last change: May 2022.
Version history: Privacy Policy