1. Data controller
The data controller responsible for processing your personal data is Numen Games S.L.
("Numen", "we", "us", or "our"), a Spanish limited liability company. You may contact us at
legal@numengames.com for any privacy-related matter.
2. Personal data we collect
We collect the following categories of personal data through our Website:
- Contact and identification data: first name, last name, email address,
company name, and any other information you voluntarily provide through our contact or
demo request forms.
- Communications data: the content of messages, project descriptions,
or queries you submit through the Website.
- Technical and navigation data: IP address, browser type and version,
operating system, referring URLs, pages visited, and time spent — collected
automatically through cookies and analytics tools.
We do not intentionally collect sensitive personal data (such as health data, racial or
ethnic origin, or political opinions). Please refrain from including such data in your
communications with us.
3. Purposes and legal bases for processing
3.1 Responding to contact and demo requests
We process your data to respond to your inquiries and arrange demos or presentations of
our Services. The legal basis is the execution of pre-contractual measures at your
request (Article 6(1)(b) GDPR).
3.2 Managing commercial relationships
If you become a client or partner, we process your data to manage the commercial
relationship, issue proposals and invoices, and deliver our Services. The legal basis is
the performance of a contract (Article 6(1)(b) GDPR) and compliance with legal
obligations (Article 6(1)(c) GDPR).
3.3 Sending commercial communications
Where you have provided your consent or where permitted by applicable law, we may send
you information about our services, news, or events. The legal basis is consent
(Article 6(1)(a) GDPR) or legitimate interest (Article 6(1)(f) GDPR). You may
withdraw consent or object at any time by contacting us at legal@numengames.com.
3.4 Website analytics and improvement
We use analytics tools to understand how visitors interact with our Website and to
improve its performance. The legal basis is our legitimate interest (Article 6(1)(f)
GDPR) in operating and improving our online presence. Where required, we obtain your
prior consent through our cookie consent mechanism.
3.5 Legal compliance
We may process your data to comply with applicable legal obligations, including tax,
accounting, and data protection law. The legal basis is compliance with a legal
obligation (Article 6(1)(c) GDPR).
4. Data retention
We retain your personal data for as long as necessary for the purposes described above:
- Contact and demo requests: up to 3 years from the last interaction,
unless a contractual relationship is established.
- Client data: for the duration of the contractual relationship plus
the statutory limitation periods under Spanish law (generally 5 years for contractual
claims).
- Commercial communications: until you withdraw your consent or object.
- Analytics data: in accordance with the retention periods set by
the relevant analytics tool (see our Cookie Policy for details).
5. Recipients and international transfers
We do not sell your personal data. We may share your data with trusted third-party
service providers acting as data processors on our behalf, including:
- cloud hosting and infrastructure providers;
- CRM and project management platforms;
- email and communication service providers;
- analytics and marketing tools.
All processors are bound by data processing agreements ensuring compliance with the
GDPR. Where data is transferred outside the European Economic Area (EEA), we ensure
appropriate safeguards are in place, such as Standard Contractual Clauses approved by
the European Commission.
We may also disclose your data to public authorities, courts, or law enforcement bodies
when required by applicable law.
6. Your rights
Under the GDPR and the Spanish Organic Law on Data Protection (LOPDGDD), you have the
following rights regarding your personal data:
- Right of access: to obtain confirmation of whether we process your data and a copy thereof.
- Right to rectification: to request correction of inaccurate or incomplete data.
- Right to erasure: to request deletion of your data when it is no longer necessary.
- Right to restriction: to request that we limit the processing of your data in certain circumstances.
- Right to data portability: to receive your data in a structured, machine-readable format.
- Right to object: to oppose processing based on our legitimate interests, including direct marketing.
- Right to withdraw consent: where processing is based on consent, to withdraw it at any time without affecting prior processing.
To exercise any of these rights, please contact us at legal@numengames.com.
We will respond within 30 days. You also have the right to lodge a complaint with the
Spanish Data Protection Authority (AEPD, www.aepd.es) or your local
supervisory authority.
7. Security measures
Numen implements appropriate technical and organizational measures to protect your
personal data against unauthorized access, alteration, disclosure, or destruction.
These include encrypted communications (TLS/HTTPS), access controls, and regular
security reviews. However, no transmission over the internet is completely secure, and
we cannot guarantee absolute security.
8. Cookies
Our Website uses cookies and similar technologies to enhance your experience and
collect analytical data. For detailed information about the cookies we use, their
purposes, and how to manage your preferences, please refer to our Cookie Policy,
available on the Website.
9. Minors
Our Website and Services are directed exclusively at business professionals and
organizations. We do not knowingly collect personal data from individuals under the age
of 16. If you believe we have inadvertently collected such data, please contact us
immediately at legal@numengames.com.
10. Updates to this policy
We may update this Privacy Policy periodically to reflect changes in our practices or
applicable law. Any updated version will be published on this page with a revised date.
We encourage you to review this policy regularly. Continued use of the Website after
publication of changes constitutes acceptance of the updated policy.
11. Contact
For any questions or requests relating to this Privacy Policy or the processing of your
personal data, please contact us at:
legal@numengames.com