We at VLYBY Digital GmbH (“VLYBY”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process* your personal data**.
The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you use our website including our platform (“Website”) which helps our clients to monetize their advertising spaces. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
This Privacy Notice applies whenever you create an account on our Website or use any of our other services, all of which together we refer to as “Services”.
* ‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
** ‘Personal data’ is any information that relates – directly or indirectly - to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.
VLYBY Digital GmbH Schwanthalerstr. 22, 80336 Munich, Germany, is responsible (“the data controller”) for the processing of your Personal Data related to the use of our Services by you.
When you use our Services, as further explained below, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.
The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:
When you use our Platform as Publisher, you provide or be asked to give us certain information, including:
In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:
We do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team.
Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:
Provision and improvement of our Services
Marketing and analytics
Compliance with our legal or regulatory obligations
Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.
We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:
Please see for additional information the section with service specific information below.
We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:
Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with by clicking here.
In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.
We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see below for information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.
If you have any queries about this Privacy Notice or how we use your Personal Data, please contact us via our Website or our Data Protection Officer via e-mail to firstname.lastname@example.org.
We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.
This Privacy Notice was last updated on: May 25, 2023.
This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.
We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:
Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D – Commercial information (such as purchase history)
Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
Category G – Geolocation data
Category H – Audio, electronic, visual, thermal, olfactory, or similar information.
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.
You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.
Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.
Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.
You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.
Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.
In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.
In order to use our Services, you have to create an account. We store your account data (log-in credentials, email address and password (encrypted)) to allow you to log in on different devices, based on the performance of a contract. Your account data will be stored for as long as your account exists. You can delete your account at any time by submitting a deletion request to our support team or by contacting our Data Protection Officer.
VLYBY is hosted and uses Webflow to provide its Services to its clients. All the above-mentioned technical information is being stored in Webflow. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality. We also share the traffic of our Website with Amazon for receiving content and delivery services. We carry out this activity based on legitimate interests on ensuring that our Website works fast and properly.
If you contact us for customer support by using our email address, we will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend possible future legal claims. In case you reach us through email, the content of the communication is also shared with Google which provides us with email hosting services. We process this data on the basis of performance of contract to provide you with customer support and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.
We process your billing and invoicing information and transfer such data to our third party service providers in order to make you payments of your revenue share from our monetization services. We process this data on the basis of performance of contract to provide you our Services.