Last updated 28th of December 2018
1. DATA CONTROLLER
Data controller means the legal person which determines the purposes and means of the processing of user data.
Controller’s name: Gaijin Network Ltd.
Address: Kyriakou Matsi, 10 Liliana Building, 2nd floor Office 203, PC 1082 Nicosia, Cyprus
2. DATA WE COLLECT ABOUT YOU
2.1. Data you provide us:
2.1.1. when you create a game account - nickname and email.
2.1.2. when you contact our support team, send your messages in chat, post your comments on the forum - data that you send at your discretion and/or with your consent;
2.1.3. when you enable the two-factor authorization - your mobile phone number;
2.1.4. when you provide us with data to send you a prize or a gift - the data that is required for delivery and/or use of the prize/gift;
2.1.5. if you participate in our surveys - the data required for participation in the survey.
2.2. Data we may collect automatically:
2.2.1. User ID generated by us;
2.2.3. Data about your device (operating system, browser type and language, manufacturer, model, screen resolution, interface language);
2.2.4. Profile data and gameplay data;
2.2.5. Traffic source (source from which the Game was installed on your mobile device);
2.2.6. General location data (if available, usually the country and the city, without identifying your specific location);
2.2.7. Gameplay data and data on interaction with other players (application installation date; version of the application; interface language; all and any quantitative and time data about your in-game activity, incl. gaming achievements, completed game tasks, in-game purchases, game results, information about in-game interactions with other players, the time of the last gaming session, information about any queries executed through the Game, etc.);
2.2.9. Data that you provide to us in the course of participating in our alpha-tests, beta-tests and other similar tests of the Game.
2.3. Data we may collect from our partners:
2.3.1. Data we collect when players link third-party services (i.e., Facebook, Mail.Ru, Gmail) with our Games, including your name (nickname), email, profile image (photo), data on your friends playing the same Game as you, depending on the privacy settings of the particular third-party service);
2.3.2. Data to fight fraud and unfair methods of play;
2.3.3. Data from platforms that the games run on (such as to verify payment; other platforms IDs);
2.3.4. Data for advertising and analytics purposes, so we can provide you a better service.
2.3.5. Data from our payment partners for sending the invoices to you when you buy something in our official store - https://store.gaijin.net.
2.4. Public data we may collect:
2.4.1. Your feedback, comments, opinions about the Games and our services published by you in the form of texts, audio recordings, video recordings on public resources.
2.5. Data we DO NOT collect:
2.5.1. We do not collect any data about your payment instruments (i.e., bankcard data, etc.);
2.5.2. We do not request or intend to collect any “special categories of personal data” (i.e., any information on your health, race, religion, political views, etc.). Kindly be cautious when sharing this information about yourself on the Websites, in game chats and on forums.
3. PURPOSES OF PROCESSING YOUR USER DATA
We use the information collected about you and your device to provide you with our Games and services and conduct our business. We pursue the following goals when processing your user data:
(1) To perform the contract with you and to enable you to play our Games, use the Websites and related services - for this purpose we do the following:
(a) operate, administer and support our Games and Websites;
(b) create user profiles, build up and maintain users database;
(c) receive bug reports, improve your game experience, improve the quality of our services, develop, improve our Games, Websites and related services;
(d) enable you to communicate with other players in chats and on forums (where available);
(e) conduct surveys and researches, analyze, integrate use the received results in an anonymized form;
(f) personalize our Games and Websites for you (i.e., by storing your preferences and settings);
(g) send you messages in order to confirm the fulfillment of certain actions by you - by mobile phone number and/or email;
(2) To show personalised advertisements and send direct marketing messages to you. For this purpose our analytics partners (see article 5.2) and some other partners may track your online behaviour and then show you personalised advertisements in the games as well as in other games and on other websites. In addition, we may produce special, personalised in-game offers for you based on the data about your use of our games. We may also send out information via your email address which contains messages about games patches and updates, news, forthcoming releases, special promotions and offers, discounts, competitions, and other events directly related to our Games. For details regarding your right to opt out of personalised advertisements and direct marketing messages, see article 6.2.
(3) To ensure security, to fight fraud and unfair methods of play - for this purpose we may monitor and analyze the behavior of players in the Games, take action against players who violate the rules of fair play, take necessary precautionary measures.
(4) To analyze all collected data, to segment and profile data.
(5) To comply with applicable laws, perform legal obligations, exercise or protect our rights, protect your vital interests or the interests of others.
4. PUBLIC USER DATA
Other players may see some of your user data. For example, other players may see your nickname and profile image (photo) as well as your nickname and account image (photo) from your social network account if you linked your social network account to your game account, they can see also your game results, posts on the Websites, messages in chats and on forums. In addition, your nickname and profile image can be viewed in game ratings (leaderboards) placed on a variety of Internet resources.
5. SHARING USER DATA WITH THIRD PARTIES
5.1. We may share your user data with any competent law enforcement body, regulatory, government agency, court for the purposes of compliance with the applicable law, response to their lawful request.
5.2. Analytics partners. We share some of your user data with our partners processing your user data for statistics, analytics and providing you with personalized online advertising ("Analytics Partners"). Such partners, for example, include Google.Analytics and Yandex.Metrics. We encourage you to check their privacy policies to learn more about their data processing practices. Analytics partners may disclose your data in aggregated manner, for the purposes of showing trends about the use of their services, for advertising services and marketing purposes. We can aggregate the data for benchmarking feature.
5.2.1. Details of using Google. Analytics.
The Games use the Google Analytics web analytics service provided by Google Inc. To learn more about how Google collects and processes your user data, visit https://policies.google.com/technologies/partner-sites?hl=en. In order to control the collection of your data by Google for analytical purposes, you can install the Google Analytics Opt-out Browser Add-On - https://tools.google.com/dlpage/gaoptout.
5.2.2. Details of using Yandex.Metrics.
5.3. Advertising partners. We may share some of Your user data (i.e. e-mail) where this is necessary for the publication, personalization (targeting) of advertisements, or for accounting purposes in relation to the advertising services being rendered by our advertising partners.
5.5. Operating partners. We may share any and all of your user data with our partners that provide the following services: (a) hosting, (b) user support, (c) testing, (d) statistical and marketing research, data analysis.
5.6. 2FA providers. We may share your data (such as mobile phone number) with partners providing Two Factor Authentication services. 5.7. Payment partners / licensees. When you purchase something at our official online store https://store.gaijin.net, we share with our payment partners your player ID and the amount of the payment. In some cases, we share your email, nickname, IP address and date of your registration in the Game with our licensees who help us to operate the Game and receive payments.
5.8. Partners for the protection against cheats and unfair play. We are using different services to protect our users from cheats and unfair play, including EasyAntiCheat service (“Easy Anti-Cheat”), which are operated by a third-party service provider offering services to us. Easy Anti-Cheat and other similar services have a client software (“Client”) that is integrated into the Games (where applicable). When you start a new Game session the Client will automatically load and install its latest version to the Unit. When you are using the Game on your Unit Easy Anti-Cheat (as well as other similar service) is monitoring the Unit, analyzing the Game binaries and scanning the memory of the Unit for the purpose of detecting and preventing cheating in the Game (“Purpose”). For the Purpose Easy Anti-Cheat (as well as other similar service) is storing information regarding cheating methods used in the Game (“Data”). The Data will contain your personal data as described in of the privacy statement of Easy Anti-Cheat. By installing, copying, or otherwise using the Game, you give your consent that Easy Anti-Cheat (as well as other similar service) may gather, store, share and publish Data for the sole purpose of the Purpose. You also acknowledge and agree that the processing activities of Easy Anti-Cheat (as well as other similar service) include automated decision-making which may have significant effects to you as you may be banned from the Game if you have been found to be cheating in it. The Data will be used solely for the Purpose including but not limited to identifying and banning player accounts which are used for cheating in computer games, analyzing cheating behavior and cheating codes, as well as sharing data about cheats with affiliates of Easy Anti-Cheat ((as well as other similar service)). You are entitled to use the Game only in accordance with applicable terms and conditions and privacy statement of Easy Anti-Cheat - www.easyanticheat.net/privacy/.
5.9. Licensees, assignees, purchasers. If we decide to assign the exclusive rights in and to the Game, appoint the licensee to operate the Game, sell the shares of Gaijin Network Ltd. to a purchaser or merger with another company, we may share your user data to the assignee, licensee, purchaser or a new legal entity formed as a result of the merger of Gaijin Network Ltd. with another company, respectively, without your additional consent.
5.10. Affiliates. Being an international company operating worldwide, we may share any and all of your user data with our affiliates (i.e. the companies control us, or being under our control, or being under common control with us), and subsidiaries. We take reasonable measures to ensure the confidentiality of your user data.
5.11. Auditors. From time to time Gaijin Network Ltd. and its affiliates may hire third-party auditing companies and therefore some of your user data (for example, your User ID, email address, list of in-game purchases) may be transferred to such companies solely for the purpose of auditing.
We operate all over the world, and therefore we may transfer your user data to our partners in the different countries including those located outside the European Union or European Economic Area. We guarantee an adequate level of personal data protection in each case. We take reasonable steps to ensure the confidentiality of your personal data transferred to the countries located outside the European Union or European Economic Area, including but not limited to, by entering into standard data protection terms adopted by the European Commission with third parties located outside the European Union or European Economic Area (a copy of which we will provide upon request).
6. YOUR RIGHTS
6.1. Right of access
You have the right to request with reasonable frequency information about your personal data we store and require us to provide you with a copy of your personal data we store or access to such data. To exercise this right, you should send us a request to our support service https://support.gaijin.net and follow the instructions provided or send us such a request directly in your personal account (where available). Please note that in some cases, to comply with a request, we may ask you to provide us with some additional information necessary to identify you as our user. We undertake to comply with your request free of charge within one (1) month of receipt, but in some cases provided by the law, this period may be extended by a further (2) two months. We have the right to refuse to comply with your request or charge a reasonable fee, if your request is manifestly unfounded or excessive.
6.2. Right to opt out of personalized (interest-based) ads and direct marketing
6.2.1. You may change the settings of your browser at any time and opt out of the analytics cookies on, in accordance with the instruction given in article 10.6.2.2. You also have the right to customize the collection and processing of your data by our Analytics partners in accordance with the instructions contained in article 5.2. 6.2.3. We may send you targeted in-game offers based on the analysis of your user data (mainly data about your in-game activity) in accordance with certain algorithms. These in-game offers do not significantly affect your rights and interests, they are designed to provide you with timely interesting (in our opinion) offers for you. However, if you want to opt out of receiving targeted in-game offers from us, please let us know by contacting our support service https://support.gaijin.net or through game settings (where available).
6.2.4. We have the right to send you direct marketing messages by email, as specified in subclause (2) of clause 3. You may unsubscribe from such mailings by following the instructions provided in the e-mail received from us. Please note that your refusal to receive direct marketing messages from us does not affect our right to send you emails specified in subclause 1(h) of clause 3. 6.3. Right to rectification
You have the right to have inaccurate personal data rectified. You can change some data about you directly in the Game settings (for example, such data as nickname or profile in social network linked to your game profile). Please inform us by contacting our support service https://support.gaijin.net if any of your personal data retained by us is inaccurate. Please note that in some cases, to comply with a request, we may ask you to provide us with some additional information necessary to identify you as our user. We undertake to comply with your request free of charge within one (1) month of receipt, but in some cases provided by the law, this period may be extended by a further (2) two months. We have the right to refuse to comply with your request or charge a reasonable fee, if your request is manifestly unfounded or excessive.
6.4. Right to erasure
You have the right to have your personal data retained by us erased by contacting our support service https://support.gaijin.net or by sending the request through your personal account (where available). Please note that in some cases, to comply with a request, we may ask you to provide us with some additional information necessary to identify you as our user. We undertake to comply with your request free of charge within one (1) month of receipt, but in some cases provided by the law, this period may be extended by a further (2) two months.
Note that complying with your request to erase your personal data will result in deletion of your game account and/or in all game results and game progress associated with your game account being irretrievably lost, so consider this when deciding to erase your personal data.
Please also note that uninstallation of the Game on your mobile device does not automatically result in the erasure of your personal data on our game servers.
We have the right to continue to retain some of your user data even after complying with your erasure request, if (1) we are required to do so in order to comply with the applicable law; or (2) you user data have been anonymized and therefore is no longer your personal data.
6.5. Right to object
You have the right to object to the processing of your personal data. Please let us know about your objections at email@example.com.
6.6. Other rights
You may have other rights in accordance with your applicable law (for example, the right to data portability is also guaranteed for European users by the General Data Protection Regulations effective of May 25, 2018). To effectuate your other rights, please contact us at firstname.lastname@example.org.
If you believe that your personal data rights have been violated, please let us know at email@example.com. You also have the right to file a complaint with your local supervisory authority about the violation of your personal data rights in the country of your location.
7. PERSONAL DATA OF MINORS
Our Games and services are not aimed at children under the age of 13 (as well as children who have not reached other applicable age of consent in accordance with the law), and we do not intentionally collect or solicit personal data from them. If we learn that we have unintentionally collected personal data from a child under 13 (or a child who has not reached the age of consent in accordance with applicable law) without the consent of his or her parental responsibility holder, we will take all reasonable steps to erase this information as soon as possible. If you find out that your child has provided us with his or her personal data without your consent, please contact us at firstname.lastname@example.org. Please provide us with conclusive evidences that (a) personal data was provided by a child who has not reached the minimum age of consent in accordance with applicable law, and (b) you are his or her parental responsibility holder.
[For our European users:
We do not exactly know the age of our users, but before the first login in the Game, we always ask each user whether he or she has reached the age of 13 or other age required in accordance with the laws of his or her country (the age of consent in the European Union varies from 13 to 16 years depending on the country), and without confirmation of this fact we do not grant access to the Game to such a user. Children who have not reached the age of consent in accordance with the laws of their country may use our Games and the Website only upon the consent of their parental responsibility holder.]
8. DATA RETENTION
We retain your personal data we collect as long as your game account is active and as long as it is necessary to provide you with access to the Games and while we have legitimate interest in processing your personal data, from the moment we receive your personal data and till the moment when we erase your personal data in accordance with article 6.4. Please note that some of your user data, as set forth in article 6.4., will not be erased even after the complying with your erasure request. We also erase your personal data after reaching the goal for which we collected them (i.e., data set forth in clauses 2.1.4., 2.1.5.).
9. INFORMATION SECURITY
In order to ensure the security of processing your personal data we constantly develop and implement technical and organizational measures to protect your personal data from unauthorized access, disclosure, misuse, alteration, loss and destruction.
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