Privacy Policy

Effective date: 2026-06-29

This Privacy Policy applies to Subiaco Baby Games ("we", "our") operating the subiacobaby.com social entertainment platform (the "Service"). We respect your privacy and are committed to protecting your personal data when you use our free social games.

Important: the Service is a non-commercial free entertainment platform. We do NOT process payments, financial transactions, or any real-money operations. The Service is provided for entertainment purposes only with virtual coins that have no monetary value.

1. Data controller

The controller of personal data is Subiaco Baby Games, operating under the laws of the Netherlands.

For privacy-related inquiries you can contact us at:

• Address: Oudegracht 156, 3511 AH Utrecht, Netherlands
• Contact: contact@subiacobaby.com

2. Data we collect

Given the non-commercial nature of the Service, we collect only what is necessary to operate and improve the platform:

• Contact information: if you reach out via our contact form or email, we collect the name, email address, and content of your message.
• Technical data: when you visit the Service, we may automatically collect your IP address, browser type and version, operating system, time and duration of visit, and pages accessed.
• Cookie data: we use cookies and similar technologies to ensure proper functioning and to analyse aggregate site usage (see our Cookie Policy).

3. Game data

In connection with the social entertainment games offered through the Service, we may also process the following types of information:

• Game session data: which games you opened, how long the session lasted, and basic interaction events (start, pause, exit). This data is anonymous and aggregated to improve game performance.
• Virtual progress data: if you choose to sign in, we may store your virtual coin balance, achieved milestones, and other in-game progress markers. These have NO monetary value and cannot be exchanged, sold, or converted into anything of real-world worth.
• Aggregated gameplay analytics: anonymised statistics on the most-played titles, average session lengths, and feature usage. This helps us improve the catalogue and platform experience.

No data we collect relates to real-money transactions, deposits, withdrawals, wagers, or anything financial — because the Service does NOT process any of these. There is nothing financial to record.

4. Purposes and legal bases

We process the data above for the following purposes:

• Service provision: enabling access to the social entertainment platform and maintaining technical operation (legal basis: legitimate interest).
• Responding to inquiries: processing messages sent via the contact form or email (legal basis: legitimate interest or consent).
• Service improvement: analysing usage data to understand how users interact with the platform and improve user experience (legal basis: legitimate interest).
• Legal compliance: meeting applicable data-protection law obligations in the Netherlands.

5. Cookies and similar technologies

Our website uses cookies to enhance user experience and analyse site usage. Cookie categories:

• Essential cookies: required for basic site functionality such as session management. Cannot be disabled.
• Functional cookies: remember your preferences and provide customised features (e.g. age-confirmation status).
• Analytics cookies: help us understand aggregate site usage patterns.

You can manage cookie preferences through your browser settings or the "Cookie Settings" link in the footer. Disabling cookies may affect site functionality. See our Cookie Policy for the full breakdown.

6. Data sharing

We do not sell, rent, or transfer your personal data to third parties for commercial purposes. We may share data only in the following cases:

• Service providers: trusted third-party providers helping us operate the platform (hosting, analytics tools). These parties process data only on our instructions and are bound by confidentiality.
• Legal requirements: we may disclose data to authorities if required by law or to protect our rights and safety.

7. Data retention

We retain personal information only as long as necessary to fulfil the purposes outlined here, or longer if required by applicable law. Inactive contact-form messages are typically retained for up to 12 months.

8. Your data protection rights

Depending on the jurisdiction you reside in, you may be entitled to exercise the following rights with respect to your personal data:

• Right to access: request information about whether and what personal data we hold about you, and obtain a copy of that data.
• Right to rectification: request correction of inaccurate, incomplete, or outdated personal information.
• Right to erasure ("right to be forgotten"): request deletion of your personal data, subject to applicable legal exceptions.
• Right to restrict processing: request that we limit how we process your data in certain circumstances.
• Right to data portability: receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to object: object to certain types of processing, including direct marketing and profiling.
• Right to withdraw consent: where processing is based on consent, withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right to lodge a complaint: file a complaint with the data protection authority in your country if you believe your rights have been violated.

To exercise any of these rights, contact us using the details in section 1. We will respond within the timeframe required by applicable law (typically within one month).

9. Security

We apply reasonable administrative, technical, and physical safeguards to protect your information. No online system is fully secure, and we cannot guarantee absolute security.

10. Age restriction

The Service is intended for users aged 18 or older. We do not knowingly collect personal data from users under 18. If you believe a minor has provided us with personal information, please contact us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time. The "Effective date" at the top reflects the most recent revision.

12. Contact

For any questions about this Privacy Policy or how we handle your data, please reach out via the contact details in section 1.