Privacy Policy

SMART NV, with registered office at Neerveld 14, B-2550 Kontich, Belgium, registered in the Crossroads Bank for Enterprises under number 0448.827.611 (hereinafter "SMART" or "we/us"), is responsible for processing your personal data in relation to SmartGames Playroom. SMART respects your privacy and personal data and complies with the applicable privacy legislation when you register on and use our website playroom.smartgames.com; a digital learning environment with educational puzzle games that train problem-solving thinking, logical reasoning, memory and analytical thinking (hereinafter "SmartGames Playroom" or the "Service"). Your registration on and use of SmartGames Playroom constitutes your acceptance of this Privacy Policy, so please take a moment to read it.

If you are under 16 years of age, we advise you to discuss this Privacy Policy with your parents, teacher or guardian.

Our cookies and your data.

1. Our Playroom cookies

A cookie is a small text file that we place on your smartphone, tablet or computer when you use this website. Cookies are necessary for SmartGames Playroom to function properly and provide us with insights into its use. When you visit SmartGames Playroom for the first time, you will be asked to accept the use of our cookies, in order to optimise your experience of the Service we provide.

We only use our own cookies, and we place and read the following cookies when you use this website:

Functional cookies: these cookies are placed by our web and game developers to ensure that our website functions as intended. We need these cookies so that you can log in, request a new password and remember your account on this device.

For the technically minded: our functional cookies are called playroom_session, XSRF-TOKEN, cookieConsent and remember_web_.

Analytical cookies: website analytics are important so that we can continue to improve SmartGames Playroom based on users' browsing behaviour and the origin of visitors to SmartGames Playroom. Your privacy is always central, and we ensure that the analysis is carried out on the basis of anonymous data. In order to obtain these data, we place analytical cookies.

For the technically minded: the names of our analytical cookies start with pk.

To obtain website analytics, we use Matomo Analytics (https://matomo.org/), an open-source tool that respects your data and is fully compliant with the GDPR. We host Matomo Analytics on our own web server in Belgium. This is one of our computers connected to the internet.

We keep anonymous information about our users' browsing behaviour: number of visits, page views, returning visits, visit duration, internet browser, device type, website goals and actions (playing a game, starting a Playroom battle, etc.). We use IP addresses to determine city and country, but not the exact location.

If you set your web browser to "I do not want to be tracked" (Do Not Track enabled), we will of course not track your visit to our website. You can enable Do Not Track by going to your browser settings and adjusting Privacy & Security settings to Do Not Track.

Marketing cookies: we use Mautic (https://www.mautic.org/), an open-source marketing tool that allows us to send marketing messages such as e-mails and newsletters. We also use Mautic to display promotional pop-ups, forms and downloads on our own website.

Mautic also runs on our own web server in Belgium as a self-hosted tool, and your data is only accessible to people working on SmartGames Playroom.

For the technically minded: the names of our marketing cookies start with mautic_and mtc_.

All these cookies are placed and read exclusively by us and are necessary for our website to function properly. The data generated by these cookies are not shared with or sold to external parties or companies. These cookies are not used for re-marketing campaigns on social media, YouTube or other external websites.

2. Third-party cookies

Good news! On SmartGames Playroom we do not use third-party cookies such as Facebook, Google Analytics, Google Ads, TikTok, Pinterest, X, WhatsApp, Snapchat, etc.

External companies therefore cannot place their marketing cookies and tracking pixels when you use this website.

3. Personal data processed by SMART

Personal data

When you play our online games, you naturally want to keep track of which games you have played, how many stars or coins you have collected, whether you play at home, in the classroom or on the go, etc.

That is why you need an account, so that we can store these data and retrieve them when you log in. We never oblige you to provide certain data. If you refuse to provide certain data, SMART may, however, deny access to certain services or aspects of SmartGames Playroom in whole or in part.

You can choose to create the following accounts:

1. Teacher account: allows you to create and manage accounts for the children in your class, view the progress of their games and assignments, and purchase a membership for your class.

2. Parent account: allows you to create and manage accounts for your children, view the progress of their games and assignments, and purchase a membership for your family.

3. Gamer account: allows you to view your own game progress and purchase a 1-player licence.

To create these accounts, we ask you for the following personal data:

• E-mail address:

  • We need your e-mail address so that you can recover your account if you forget your password, or so that we can send you invoices or Playroom updates by e-mail. You can subscribe to or unsubscribe from our newsletters at any time via your account page.

• Username and password:

  • We need a username and password to enable you to use SmartGames Playroom. Passwords are stored securely and encrypted (encoded), i.e. in an unreadable format.

• Payment details are not processed or stored on SmartGames Playroom. To make payments, we use the online payment platform Mollie (<www.mollie.com>).

Providing these personal data to SMART is regarded as consent for SMART to process these data.

Sharing your first and last name is optional.

In principle, SMART does not process personal data of minors. When an adult creates an account, it is expected that he or she shares his or her own personal data - not those of the minor. If an adult nevertheless shares personal data of a minor with SMART, that adult is responsible for doing so.

Payments for our memberships are processed via the online payment platform Mollie. We do not keep payment data ourselves. You can read Mollie's privacy statement at https://www.mollie.com/gb/legal/privacy. With the exception of Mollie, we do not share personal data with other companies or external parties.

Playroom data

When you play our games, we record the following data:

• Number of stars won

• Number of coins won

• Time taken to solve a challenge

• Number of moves to solve a challenge

• Number of "undo's" to solve a challenge

• Number of resets to solve a challenge

No one has access to your data except your teacher, parent, or the people working on Playroom games, the website, the mobile applications and the web server.

4. Security

SMART takes great care to protect your personal data and has taken the following measures:

• Your data are stored securely in a non-public database in Belgium and we make a daily back-up;

• Our websites and applications are secured via a Secure Socket Layer (SSL) certificate, which renders the data you send to and receive from our server unreadable;

• Your data and personal data are never sold to or shared with external parties or companies;

• We do not use third-party cookies and trackers;

• Player profiles, including usernames, passwords and e-mail addresses, are not public;

• You can delete your account at any time via the "Delete my account" button on the "Edit my account" page (https://playroom.smartgames.com/en/profile/edit).

• We keep your personal data only for as long as strictly necessary; i.e. for as long as these data are required by SMART to provide its Service and to give the user access to SmartGames Playroom. As soon as SMART or the user cancels the account, or the user's account is deleted, SMART will stop processing the personal data after a period of 24 months. This period is intended to give you the opportunity to reactivate your account if desired.

Although SMART takes the necessary security measures, the user remains responsible for careful use and safekeeping of his or her personal data. If you believe that your account has been hacked, lost or stolen, please inform us as soon as possible.

5. Your rights

You have the right to access your data, to correct them, and to have them deleted by sending an e-mail to privacy@smart.be.

You can also send us a letter to the following address:

Smart NV
Neerveld 14
2550 Kontich
Belgium

SMART reserves the right to verify the identity of the applicant in the event of a request for access, correction or deletion of personal data.

You may also contact the Belgian Data Protection Authority at any time: contact@apd-gba.be, address: Drukpersstraat 35, 1000 Brussels.