Privacy Statement - Heroes Inc (GAMEMKRS B.V.)

Effective Date: January 1, 2024
Version: 2.0 - Global Privacy Statement for Heroes Inc Projects

1. Who we are

GAMEMKRS B.V. ("Heroes Inc," "we," "us") designs and operates interactive learning games, digital workshops and immersive experiences - including but not limited to Future Game, Pop-Up Escape Room, Game Plan (collectively referred to as "the Apps" or "the Games").

We are committed to protecting your privacy and handling personal data with care, in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

Controller: GAMEMKRS B.V.
Registered address: Tappersweg 14-027, 2031EV Haarlem, The Netherlands
Contact: info@helden-inc.com

2. What data we collect.

When you participate in our events or use our digital applications, we collect and process only the data necessary for game play, reflection and evaluation. Depending on the project, the following categories of data may be collected:

Game and event details

Team name or identifier (used for in-game tracking)
Game interactions, including:
- Multiple-choice answers
- Open-text words
- Results of minigames
- Game progress and score
Answers to questionnaires collected during the game
Reflection answers and short feedback responses
Reviews and comments on the gaming experience

Technical data

We do not collect or store device information such as IP address, device ID, browser or operating system.
We do not use cookies, tracking pixels or analytical tools within our gaming applications.
When you visit our website (heroes-inc.com), we may collect limited technical data through standard web analytics (e.g., page visits, anonymized session data) to improve website performance. These analytics are aggregated and not traceable to individual visitors.

3. Why we collect this data.

We process your data to:

Manage game mechanics, progress, scores and storyline.
Show game results and calculate team outcomes.
Analyze anonymized interaction patterns to improve our games and educational impact.
Evaluate the effectiveness of workshops and trainings.
Collect optional feedback and reflections from participants for research and product improvement.
Ensure the technical functionality and user experience of our website.

4. Legal basis for processing.

We base our data processing on the following legal grounds under the General Data Protection Regulation (GDPR):

Performance of a contract (Article 6(1)(b) AVG):
To deliver the core functionality of our games and digital experiences.
Legitimate interest (Article 6(1)(f) AVG):
To analyze anonymized data and improve our services.
Consent (Article 6(1)(a) AVG):
For optional input fields (such as reflections, feedback or ratings).
Participants may withdraw their consent at any time without affecting the lawfulness of previous processing.

5. Who is responsible for your data

When Heroes Inc offers the App or event directly to participants, we act as the data controller.
When our games are offered on behalf of a client organization (e.g., a museum, university or corporation), that organization is the data controller, and Heroes Inc acts as a processor, according to the client's written instructions and under a data processor agreement (DPA).

6. Data sharing and disclosure

We do not sell or share personal data with third parties for marketing purposes.

Infrastructure provider:
Data is securely stored on Microsoft Azure (Western Europe), which acts as our data processor.

Other third parties:
We may disclose data only if required by law or to protect the security of our systems.

7. Storage location and retention period.

Storage Location:

All data is stored within the European Economic Area (EEA) on Microsoft Azure servers (Western Europe).
We do not transfer personal data outside the EEA.
If an international transfer is necessary, we will apply appropriate safeguards, such as EU Standard Contractual Clauses (SCCs).

Retention period:

Until 1 month after an event, we delete all personal and identifiable data, such as team names, open-text answers, ratings and reflections.
Anonymized game data (such as aggregated answers or mini-game results) may be retained indefinitely for research, analysis and product benchmarking.
These datasets cannot be traced back to an individual.

8. Security

We employ strict technical and organizational measures to protect data from unauthorized access, modification or disclosure, including:

Encryption during shipping and storage
Role-based access management
Logging and monitoring of system access
Access granted only to authorized personnel
Hosting within Azure-certified environments (ISO 27001, 27017, 27018)

9. In-app privacy statement

In many of our games, participants will see a brief privacy statement when they launch the App:

"We occasionally ask you to share short answers or thoughts. All input remains confidential and is only used internally. We handle your data with care."

10. Rights of participants

Depending on your location, you may have the following rights under applicable privacy laws:

Access to your data
Requesting correction or deletion
Objecting to or restricting processing
Revoke consent at any time
Filing a complaint with your local supervisory authority

Requests can be sent to info@helden-inc.com.
If your data was collected under a project on behalf of a client organization, please contact that organization directly; Heroes Inc will assist them in handling your request.

In the Netherlands, you can also contact the Personal Data Authority:
📍 www.autoriteitpersoonsgegevens.nl

11. Updates to this privacy statement

We may update this statement to reflect changes in our practices or legal obligations.
Important changes will be announced via our website and/or in the App.
The most recent version is always available at www.helden-inc.com/privacy.