Privacy Policy

I. Controller, Scope

Love & Lust is a service provided by Sirob OÜ (hereinafter also referred to as “Sirob” or “Provider”), acting as Controller in accordance with relevant data protection provisions. Please, find here full company and contact details:

  • Sirob OÜ, Sepapaja 6, 15551 Tallinn, Estonia
  • Sirob can be contacted via email at info@sirob.eu

The protection of personal data has the highest priority for us. We would therefore like to inform you about which data we collect when, and how we process your personal data. This privacy notice describes the collection and processing of personal data on the website https://www.loveandlustgame.com (hereinafter referred to as "Website") and the app Love & Lust available on the Apple App Store and Google Play Store (hereinafter referred to as "App").

II. General information about data processing

1. Purposes of processing

In principle, we only process personal data of users as necessary to provide our contents, a functional Website and App, and to provide our services.

2. Legal basis for the processing of personal data

We mostly process personal data according to one of the following legal bases:

consent

Whenever we collect the data subject’s consent to the processing of personal data, Art. 6 para. 1 a EU General Data Protection Regulation (GDPR) serves as the legal basis.

contract or pre-contractual measures

If the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

legal obligation

If the processing of personal data is necessary for compliance with a legal obligation which the Controller is subject to, Art. 6 para. 1 c GDPR serves as the legal basis.

legitimate interests

If processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party and if such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 f GDPR serves as the legal basis.

3. Data erasure and retention time

In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent.

Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.

4. Transfer to third countries

Unless otherwise stated, all data processing operations take place within the EU or the EEA countries.

Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations.

A transfer of personal data outside the EU or the EEA shall only take place on the basis of an adequacy decision of the European Commission or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. A list of current adequacy decisions (as well as information about the effect of the ECJ’s ruling in the case C-311/18 on Privacy Shield) is available on the European Commission's website.

III. Processing of personal data in general

Regardless of whether you utilize any of the Website’s features, we automatically collect data about your use of the Website. This includes in particular the accessed URL, access date and time, transferred data volume, http status code of the access reply, web browser type and operating system, HTTP referrer, as well as IP address. This information is not associated with your person.

We collect and process such data to ensure Website operation and availability. In addition, it is used to analyse, store and evaluate information about user behaviour anonymously and to continuously improve and further develop our service. We only store your IP address in the log files for a limited period of time, if this is necessary for security purposes.

These purposes constitute our legitimate interest, which justifies data processing pursuant to art. 6 par. 1 lit. f) GDPR.

IV. Processing of personal data when using the Website

1. Information we collect

To provide a seamless gaming experience, the following data is stored locally:

  • Player names, avatars, and genders
  • Game mode, custom and saved Love cards
  • Game settings (e.g., sound preferences)
  • Card interactions (likes, dislikes, count, and last seen date)
  • User information & preferences (e.g. relationship length, content preferences)
  • Current game state, preferences and set-up

For the web version, this data is saved in your browser's local storage. On Android and iOS apps, it’s stored in the local file system. When logged in, this data is synced to our server, along with your email address for login and data synchronization purposes.

Photos uploaded in the game are never synced or stored on our server, only kept locally on your device.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Personal data may be freely provided by the data subject or, in the case of data regarding the way the application is used, collected automatically when using Love & Lust. Unless otherwise specified, all data requested by this application is mandatory. If the data subject refuses to communicate them, it may be impossible for this application to provide the service. In cases where some data is indicated as optional, users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who wish to know more about the data we collect are encouraged to contact the Controller.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

Any use of Cookies - or other tracking tools - by this application or by the owners of third-party services used by this application has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document.

The User assumes responsibility for the personal data of third parties obtained, published or shared through this application.

2. How we use your information

On our Website and our App you may create a user account. In order to create the account, you only have to provide a valid email address. We need this information in order to be able to associate your users account to you and to keep track of your activity on our Website and our App. Failure to provide the data will result in unavailability of our services.

User accounts and all information stored therein shall be retained on our servers for as long as you do not request account deletion. Account deletion can be requested via e-mail, using the contact details specified in this policy.

We adopt appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of personal data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.

In addition to the data controller, in some cases, other parties involved in the organization of Love & Lust (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as data processors by the data controller. The updated list of processors can always be requested from the data controller.

The data is processed at the data controller's operational offices and in any other place where the parties involved in the processing are located. Personal Data may be transferred to a country other than the one in which the data subject is located.

We use the information we collect in various ways, including to:

  • Provide, operate, and maintain our website and our app
  • Improve, personalize, and expand our website and our app
  • Understand and analyze how you use our website and our app
  • Develop new products, services, features, and functionality
  • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
  • Send you emails
  • Find and prevent fraud

V. Data Processors

In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf (“Processors”). This applies for instance to hosting providers. None of these actors shall process your data for their own purposes. The scope of this processing is defined pursuant to art. 28 GDPR.

The categories of third-party processors we currently work with or may work with in the future are as follows:

  • Email marketing services: We use services such as Flodesk and Mailchimp to manage our email communications with you.
  • Survey and feedback collection tools: We use services such as Google Forms to collect feedback from users.
  • Payment processing services: We rely on payment providers such as Paddle, LemonSqueezy, and FastSpring to facilitate secure transactions.
  • Hosting and content delivery services: Our hosting provider, Akamai, ensures that our website and services are reliably delivered to you.

We only work with processors who can guarantee compliance with GDPR standards and who will not use your data for purposes other than those defined by us.

VI. Processing in compliance with a legal obligation

Please note that, in addition to what specified in this privacy notice, your data may be processed in compliance with legal obligations which we are subject to. For instance, we may be obliged to store your data for a legally determined period to comply with tax law provisions. Please contact us in case you want to learn further details about such processing activities.

In such cases the legal basis of the processing is art. 6 par. 1 lit. c) GDPR.

VII. Use of Tracking technologies

1. Description and scope of data processing

In order to improve user experience of our Website and to enable selected functions, we implement cookies or other tracking technologies (hereinafter jointly referred to as “Cookies”) on various pages. These are small data sets being stored on your device. Some of the Cookies we use expire after the end of the browser session, i.e. after closing your browser (so-called session Cookies). Other Cookies remain on your device and enable us or our partner companies to recognize your browser or device on your next visit (persistent Cookies).

You can set your browser preferences in order to be notified about the setting of Cookies and decide individually about accepting or refusing them in certain cases or generally. You can also manually delete Cookies from your device at any time.

Failure to accept Cookies may result in minor limitations in our service’s functionalities.

Cookies are stored on the user's computer and from there transmitted to our site. Therefore, you as a user have full control over the use of Cookies. You can deactivate or restrict the transmission of Cookies by adjusting the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If Cookies are deactivated for our Website, it may no longer be possible to use all functions of the Website in full. You can also manage your cookie preferences via recognized third-party services such as http://www.youronlinechoices.eu/ (if you’re based in the EU).

2. Strictly necessary Cookies

Some of the Cookies we use are strictly necessary to allow us to deliver the service you requested or to operate our Website. Some elements of our Website require that your browser be identified after page changes. Such technical Cookies may collect personal information about you, such as IP address, log-in information, etc.

The processing of personal data through strictly necessary cookies – if any – is art. 6 par. 1 lit. f) GDPR. In case such cookies are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1 lit. b) GDPR.

3. Other Cookies

The web version of the game uses several cookies to manage authentication and ensure smooth gameplay. These cookies track your session and facilitate communication between the authentication window and the game logic. They include: "love-and-lust-auth", "messages", "sessionid", and a hashed cookie for added security.

Moreover, a "csrftoken" cookie is used to secure communication between the client and server during authentication, ensuring that your data remains protected from unauthorized access. These cookies are vital for maintaining a secure and seamless user experience.

In addition, we use third-party Cookies to monitor and evaluate user behaviour for statistics and market analysis purposes. Such Cookies are provided by third parties and implemented in our Website. Please refer to the following sections for details. Such Cookies allow us to analyse your use of our service and improve it continuously. Analytics allow us to offer you a better service that meets your interests better.

Unless otherwise specified, the legal basis of processing through other Cookies mentioned below is your consent pursuant to art. 6 par. 1 lit. a) GDPR. Unless otherwise specified, the lifetime of Cookies used based on your consent expires upon withdrawal of your consent.

GOOGLE ANALYTICS

We implement "Google Analytics". Google Analytics is a web analysis service provided by Google Inc. The information generated by the Google Analytics Cookie about your use of our Website is generally transmitted to and stored by Google on servers in the United States. IP anonymization has been activated on our Website: this means that the IP address of users based within the European Union or the European Economic Area is abridged, and therefore anonymized, before being transferred abroad. Only in exceptional cases is the unabridged IP address transferred to a Google servers in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, to draft reports about Website activity and to provide us with other services relating to Website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not put in relation with other Google data. You may object to the use of Cookies by selecting the appropriate settings on your browser, however please note that doing so may result in limited functionality of this Website. You can also prevent Google from collecting the data generated by the Cookie and relating to your use of the Website (including your IP address) and processing this data by installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

To find out further information about how Google handles personal data, please refer to Google's privacy policy: https://policies.google.com/privacy?hl=en.

MAMOTO

“Mamoto” uses cookies to enhance functionality and improve user experience. On our website, Matomo Analytics tool ensures user privacy by anonymizing data, masking the last two bytes of IP addresses, and tracking without cookies—except when a user opts out of tracking. In this case, a cookie is used solely to remember the opt-out preference, preventing tracking on future visits. Additionally, only the domain of referrer URLs is stored, further protecting privacy. Users can manage cookies via browser settings. For more details, refer to MAMOTO's privacy policy: https://matomo.org/privacy

VIII. CCPA Privacy Rights (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

  • Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
  • Request that a business delete any personal data about the consumer that a business has collected.
  • Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

IX. Data Subjects’ rights

As a data subject, you have the following rights pursuant to the GDPR:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to notification - If you have exercised your right to have the Controller rectify, erase or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.

Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section.

Your right to withdraw consent - You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please reach out for us at the contact details indicated on the Website if you wish to make a request.

Your right to file a complaint - You can also complain to a data protection authority if you do not agree on how we have used your data.

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

X. Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Love & Lust does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

XI. Amendments to this privacy notice

Due to the dynamic development of the Internet, new technologies and possibilities are constantly developing. To enable us to offer you these possibilities and technologies, we reserve the right to change this privacy notice for the future when introducing new, additional or when changing or extending existing services or service elements. The new privacy notice shall apply from the date of its update on the Website.