Privacy Policy
Version: 1.1 · Last update: 31 August 2026
This Privacy Policy describes how 64 Software Train (“64 Games” or the “Controller”) processes the personal data collected through the website https://ploomies.com (the “Site”).
The Site is purely informational: it has no forms and collects no identifying data provided by the user. The only data processed is that derived from the cookies described below.
1. Controller
- Identity: 64 Software Train
- Tax ID: B56899636
- Registered address: Polo de Contenidos Digitales, Av. Sor Teresa Prat 15, 29003 Málaga, Spain
- General email: nacho@64train.com
- Privacy email: nacho@64train.com
- Data Protection Officer (DPO): Not appointed
2. Purposes and legal bases
64 Games processes personal data for the following purposes and legal bases:
2.1. Web analytics (analytical cookies)
- Data: cookie identifiers (
_ga,_ga_*), truncated IP, technical device data (browser, OS, resolution), pages visited, time on page, interaction events (CTA clicks, scroll, video play). - Purpose: analyze aggregated user behavior to improve the Site, optimize content and measure marketing effectiveness.
- Legal basis: consent (art. 6.1.a GDPR and art. 22.2 of Spanish Law 34/2002 LSSI-CE), via the cookie banner.
- Retention: up to 14 months (Google Analytics 4 default). Consent can be withdrawn at any time from “Cookie settings” in the footer.
- Recipients / international transfers: Google Ireland Limited (processor) and Google LLC (United States). The transfer to the U.S. is covered by the EU-U.S. Data Privacy Framework Adequacy Decision (July 2023) and Standard Contractual Clauses (SCC).
2.2. Technical cookies
- Data: Site-owned identifiers (
ploomies_consent,ploomies_lang). - Purpose: store the user’s consent decision and language preference.
- Legal basis: Controller’s legitimate interest (art. 6.1.f GDPR) and technical necessity (exemption art. 22.2 LSSI-CE).
- Retention: 12 months for
ploomies_consent; session forploomies_lang.
3. Data recipients
Except for legal obligation, 64 Games does not transfer personal data to third parties other than the providers listed under each purpose (processors). In particular:
- Web analytics provider: Google (Google Analytics 4).
- Hosting provider: Oracle Cloud Infrastructure (Oracle Corporation and its affiliates), with servers in the Madrid (Spain, European Union) and Mexico regions. As there is no European Commission adequacy decision for Mexico, the international transfer relies on the Standard Contractual Clauses (art. 46.2.c GDPR).
All processors have signed the corresponding agreement under art. 28 GDPR.
4. Data subject rights
Under arts. 15-22 GDPR and the Spanish LOPDGDD, users have the following rights:
| Right | What it allows |
|---|---|
| Access | Know what data 64 Games processes. |
| Rectification | Correct inaccurate data. |
| Erasure (“right to be forgotten”) | Request deletion when no longer necessary. |
| Objection | Object to processing based on legitimate interest. |
| Restriction | Restrict processing while resolving complaints. |
| Portability | Receive data in a structured, machine-readable format. |
| Withdraw consent | Without retroactive effect. |
| Not be subject to automated decisions | Including profiling. |
How to exercise: by email to nacho@64train.com with subject “GDPR rights” and a copy of an ID document.
Response time: 1 month (extendable to 2 in complex cases), under art. 12.3 GDPR.
Right to lodge a complaint: if you believe your rights have not been properly addressed, you can file a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan, 6, 28001 Madrid, Spain. Web: https://www.aepd.es. Phone: +34 901 100 099.
5. Security
64 Games applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption in transit (TLS 1.3), access control, activity logs, backups and staff training.
In the event of a personal data breach posing a high risk to the rights and freedoms of natural persons, 64 Games will notify data subjects without undue delay, in accordance with art. 34 GDPR.
6. Minors
The Site is not directed at children under 14 years old (minimum age for valid consent in Spain under art. 7 LOPDGDD). We do not knowingly collect data from children below that age. If a parent or legal guardian detects that a minor has provided their data without authorization, they can request immediate deletion by writing to nacho@64train.com.
For the video game itself (when launched), the recommended minimum age will be determined by the corresponding PEGI / ESRB / IARC rating, which will be published in due course.
7. Changes
64 Games reserves the right to modify this Privacy Policy to adapt it to legislative or jurisprudential developments and industry practices. The last update date is shown at the top. As there is no mailing list, any change is published on this page along with its update date.
Prevalence clause: This is a translation for reference. In case of discrepancy, the Spanish version of this Privacy Policy prevails (https://ploomies.com/es/politica-privacidad).
Drafted in accordance with Regulation (EU) 2016/679 (GDPR), Spanish Organic Law 3/2018 (LOPDGDD), Spanish Law 34/2002 (LSSI-CE) and Directive 2002/58/CE (ePrivacy).