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The Privacy Policy

Effective Date:  This Privacy Policy was last revised on August 21, 2013.


Welcome to Habbo Hotel, an online social entertainment site where people can create their own Habbos, have fun, hang out, play games, and make friends.  Habbo Hotel is owned and operated by Sulake Corporation Oy (“Sulake,” “we,” “our” or “us”).  Sulake respects your privacy concerns and recognizes that visitors to Habbo Hotel need to understand how their information may be used or shared. 

This “Privacy Policy” governs your use of our site at www.habbo.com, and any other of our sites that post a copy of it  (including both mobile and online versions of our site), including such interactive features, widgets, applications, content or downloads that we own and make available in connection with such site(s) (collectively, the “Service”) regardless of how you access or use them, whether via personal computers, mobile devices or otherwise, but does not apply to data we receive from third parties, except to the extent we combine such data with Customer Data (defined below) that we have ourselves collected under this Privacy Policy.  This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below). 


1. Data Controller

Sulake Corporation Oy

Porkkalankatu 1

00180 Helsinki, Finland

Tel. +358 10 656 7000

Fax: +358 10 656 7010


2. Name of the Register

Habbo.com Customer Database


3. The Purpose For Processing Your Data and the Use of Our Register

We use Customer Data (defined below) and other data about you for the following purposes:

  • Administering and maintaining the customer relationship with our customers and operating the Service.
  • If the customer has agreed, to sending newsletters and other information (including marketing information) about Habbo and other Sulake products.
  • For keeping the Habbo Hotel safe and other administrative and safety reasons, e.g. investigating fraud and other criminal actions and helping the police with the investigations.
  • Complying with applicable law, and to the extent permitted by applicable law, cooperating with requests by government and by third parties that allege their rights have been violated.
  • Planning and developing our business activities, as well as our affiliates and subsidiaries, with the help of different research methods.
  • Serving you content and advertising directly, as well as through our affiliates and subsidiaries and our relationships with third-party vendors.


4. Content of the Register

  • “Customer Data” includes:

- E-mail address.

- IP-address, and other persistent identifiers (“Device Identifiers”).

- Date of birth.

- Telephone/mobile number if the customer has submitted it upon registration, has made purchases with a telephone/mobile or otherwise submitted that information.

- The identifier number of a Third-Party Site or Apps profile and the profile data relating to that identity if the customer registers through a Third-Party Site or Apps login (for example Facebook, Twitter). The profile data may include, but is not limited to, your name, profile picture, gender, customer ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile

  • “Usage Data” (transaction information, usage behavior and preferences, purchase information, access logs, moderation actions).
  • Chat Log.  We may log chats for safety and moderation reasons.
  • Submissions.  Content and other data you submit to us.
  • Location data. To the extent Sulake makes location enabled Service available and you use such Service, Sulake may collect and process your location data to provide location related Service and advertisements. For example, your Habbo friends nearby your location may get information about your location or you may get friend suggestions about Habbo customers nearby your location. Sulake may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS geo-location is not accessed without your consent. Notwithstanding Sulake’s partners who are providing location related parts of the Service, Sulake will not share your GPS geo-location with third parties without your consent. To the extent Sulake makes available GPS geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously.


5. Regular Sources of Information

Data is collected through customers’ interaction with us, including our affiliates and subsidiaries, as well as by third-party vendors, including without limitation:

  • completion of online forms (such as the registration form).
  • participation in contests and surveys.
  • subscription for certain newsletters and enhanced services.
  • posting of messages to the message boards and chat services.
  • emails or other communications with us.
  • Tracking Technologies (defined below) such as cookies and web beacons.


6. Regular Destinations of Disclosed Data and Whether the Data is Transferred to Countries

Outside the European Union or the European Economic Area

We do not regularly disclose data to third parties, except to our affiliates and third parties we engage to provide services for us (e.g., site development, operations and moderation).  Some of these third parties such as analytics providers, advertising services providers and advertisers, may collect data from you themselves via our Service or services, but we are not responsible for them and their own privacy policies govern their practices. 

Notwithstanding anything to the contrary, the data may be disclosed to police or other authorities, or to third parties alleging a violation of their rights, if required or allowed by the law.

Information may also be disclosed for research and marketing purposes if the customer has given a consent for such disclosure.

Your data may also be disclosed to financial institutions, and authorities and our payment partners in specific cases when a fraud is inspected as well as to the payment partners as part of the normal payment process and risk management.

Furthermore, the data may be transferred to other companies within Sulake.

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world in accordance with mandatory legislation and this Privacy Policy.  If you are located in the European Union / European Economic Area, or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including Customer Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Policy.


7. The Principles of How the Data File / Register is Secured

Access to Sulake data relating to our customers is granted to Sulake’s employees or contractors if reasonably required by their work duties.  Access is controlled through security procedures such as by using individual Sulake-issued certificates and user-names/passwords and logging data access and actions.  Although we take measures to secure your data, no data security is without risk and we cannot guarantee security and you transmit data to us at your own risk. 


8. The Use of Cookies, Web Beacons and Other Technologies

We may use a variety of now and later developed methods and technologies, such as “cookies”, that automatically (or passively) collect and/or store certain information whenever you visit or interact with the Service (“Tracking Technologies”), which technologies may be downloaded to your computer or device and may set or modify settings on your computer or device.  A “cookie” is a data file placed on a computer or device (such as your browser) when it is used to visit the Service. We use Tracking Technologies that are strictly necessary to allow you to use and access the Service, including cookies required to prevent fraudulent activity or improve security.  We may decide in the future to use Tracking Technologies to help us deliver content, including advertisements, relevant to your interests as part of your use of the Service and third-party sites.  By using this Service, we are seeking to obtain your consent to use these various Tracking Technologies.

You may exercise control over regular cookies insofar as they may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some instances can be blocked in the future by selecting certain settings.  Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.  By choosing to disable cookies, however, you may not be able to benefit fully from the Service (e.g., some or all of it may not continue to work as intended).

A “web beacon” is another type of Tracking Technologies we may use, which we may use to track who is reading a web page or e-mail, when, and from what computer or other device.  We use them to provide better service to you.  We may use web beacons to recognize the visitors generated from our online and e-mail campaigns as well as to monitor our customers’ readership levels to identify aggregate trends and individual usage.  We may link Customer Data and other data about you to the web beacons. We may decide in the future to use web beacons to help us deliver content, including advertisements, relevant to your interests as part of your use of the Service and third-party sites.

This Privacy Policy does not govern the Tracking Technologies that may be employed by others in connection with our Service, such as analytics vendors, advertising networks, advertisers and third-party applications and plug-ins (e.g., social media site apps and plug-ins) that you may access via our Service.  You should refer to the privacy policies of these parties with regard to their data practices. 


9. Children

Our Service is a general audience website intended for customers 13 and over and we do not intend to collect personal information from customers under the age of 13. If you are a U.S. parent and suspect your child under 13 years of age has submitted Customer Data to us, contact us here.


10. Information Third Parties Provide About You

We may receive information about you from your friends and others that use the Service, such as when they submit content to us or post on the Service.  Additionally, we may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content and advertising to you and to offer you opportunities that may be of interest to you.  To the extent we combine information we receive from those sources with Customer Data we collect on the Service, it will be treated as Customer Data and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise.  In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.


11. Information You Provide About a Third Party

You may send someone else a message from the Service, such as an invitation to a friend on the condition that you have the consent of such person.  Sulake may offer you the opportunity to invite your contacts from Third-Party Sites, (such as your Facebook friends or Google address book contacts) so that those contacts can be located in Habbo and/or you can invite them to friend you in Habbo. The information you provide or allow the Service to access (names, e-mail addresses, mobile number, Third-Party Site or App identifier number, location data etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise.  Please be aware that when you use any share-with-a-friend functionality on our Service, your e-mail address, mobile number, name or user-name, and message may be included in the communication sent to your addressee(s).  Some of these tools may be third-party tools subject to third-party privacy policies as further detailed in Section 12You or the friend may contact us at sarrequests@sulake.com to request a removal of this information from our database.


12. Interactions with Third-Party Sites, Apps and Content

The Service may include functionality that allows certain kinds of interactions between the Service and your account on a third-party website or application. We may also use third parties to facilitate e-mails, tweets or Facebook postings and we may provide links off of our Service to third-party sites (including of advertisers), including facilitating you sending a message from the Service or accessing third-party content or locations.  The use of this functionality may involve the third-party operator providing certain information, including Customer Data, to us.  For example, when you register with the Service, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Service.  If we offer and you choose to use this functionality to access our Service, the third-party site or application may send Customer Data about you to the Service.  If so, we will then treat it as Customer Data under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Service. The Service may also contain content that is supplied by a third party, and those third parties may collect Usage Data and your Device Identifier when pages from the Service containing third-party content are served to you.  We are not responsible for the data collection and privacy practices employed by any of these third parties, and they may associate their own Tracking Technologies with you, independently collect data about you, including Customer Data, and may or may not have their own published privacy policies.  We also encourage you to note when you leave our Service or otherwise interact with third-party content or applications and to review the applicable third-party privacy policies and exercise caution in dealing with third parties.


13. You May Request Changes to the Information We Collect About You and Set Communication Preferences

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.  The Service may allow you to review, correct or update Customer Data you have provided through the Service’s registration forms or otherwise, and you may provide registration updates and changes by contacting us .   


If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.  With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application.  You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. 

When you edit your Customer Data or change your preferences on the Service, information that you remove may persist internally for our administrative purposes.  Also, please note that it is not always possible to completely remove or delete all of your Customer Data from our databases and that residual data may remain on backup media.  In addition, if you have made any public postings on the Service such as in forums or blogs, these communications will not generally be removed.   

You may opt-out of receiving e-mail marketing communications from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Service account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited.  If you subscribe to text messages from us, you can terminate a particular text message subscription by reply texting “STOP.”  Subsequent or different subscriptions will be unaffected.  Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways:


Postal Mail: Sulake Corporation Oy, Porkkalankatu 1, 00180 Helsinki, Finland

E-mail: sarrequests@sulake.com


14. Security

Sulake takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.  Although we make good faith efforts to store the customer information collected on the Service in a secure operating environment that is not available to the public (excepting information you have posted publicly on the Service), we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.  Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.  We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties.

    

15. Changes To The Privacy Policy

We will continue to evaluate this Privacy Policy in order to keep up with changing customer needs, enhanced technologies, and as we develop new service offerings, and we may make changes to the Privacy Policy accordingly.  We reserve the right to modify this Privacy Policy at any time, so please review it frequently.  When changes are made to this Privacy Policy, we will revise the “Effective Date” found at the beginning of this Privacy Policy.

If we make any material changes to our privacy practices that may impact you, we will prominently send you a minimail or post other notice of the changes on our Service for a period of at least 30 days.

To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.


16. How To Contact Us

Questions and comments about our Privacy Policy should be mailed to: Sulake Corporation Oy, Porkkalankatu 1, 00180 Helsinki, Finland.


//End Privacy Policy//

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