By “Personal Data”, we refer to data that relates to you as an identified or identifiable natural person. The term “Personal Data” may include your name, your address, your telephone number, your e-mail address, your age, your gender, your game preferences, for instance. Anonymous information, which we are not in a position to relate to you, does not qualify as “Personal Data”.
1. CONTROLLER’S NAME AND CONTACT DETAILS
Controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding our online and mobile games including, but not limited to, “Fightttris VR”, “Post Apocalipse Express”, associated web-sites as as well as any other TECHHOME games and any other websites owned or operated by TECHHOME:
Tonnelnaya st 2a office 403,
Both entities are referred to as “TECHHOME”, “we”, “our” and “us” in this Policy. The term “Services” refers to the act of providing you with the opportunity to use the named games (“Games”), websites (“Sites”), TECHHOME account (“Account“), any of our other products and services (including support services, forums) related to the Games (“Ancillary Services“). 2. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO) The contact details of Data Protection Officer of TECHHOME are: "TECHHOME" LLC,
Tonnelnaya st 2a office 403,
3. GENERAL INFORMATION IN BRIEF
We process personal data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms for which require the protection of your Personal Data.
Our legitimate interests are to render and improve our Services in an effective, safe and harmless manner. We want to provide everyone with a fair and balanced experience when using our Services.
3.1. INFORMATION SECURITY
We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
3.2. PROCESSING INFORMATION BY THIRD PARTIES
We may share Personal Data with our affiliates, subsidiaries, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services. Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Those companies may be located outside of the European Economic Area. Read more in Section 6 “How we share your information”.
We recognise that we have a special obligation to protect personal information obtained from children. We will not knowingly collect Personal Data from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law).
3.4. DATA RETENTION
We keep most of your Personal Data gathered and processed for the purposes described in this Policy for as long as you continue to use our Services. The process of erasing your Personal Data can take up to one month from expiry of the grace period and, considering the complexity and number of requests, may be extended by a further two months. Read more in Section 7.4 “Right to erasure”.
4. INFORMATION WE COLLECT
In relation to your use of our Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g. through our Site’s technology).
4.1. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, your use of certain Services is possible only if you provide required information.
We may obtain your Personal Data when you register for and use our other Services, e.g. game forums, chats, or when you provide feedback about our Services. This data includes:
Information that you post, comment or like in any of the Games-related forums owned or operated by TECHHOME (“Forums”), on the pages of social network groups operated by TECHHOME, and on the Sites;
Information sent through the “game-chat” functionality in the Games, including through in-Game voice chat;
Information you provide when you request information or support from us or purchase a product or service from us, including information necessary to process your orders with the relevant payment merchant, which may include the amount of any transaction, but will not include your financial information, which will only be submitted directly to the payment merchant under secure protocols;
Information that you provide to us to become a participant of alpha-tests, super tests, and UX tests.
4.2. INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our Games, Sites and other Services. This information may include, but is not limited to, anonymized browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information (“Other Information”). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If Other Information is combined with Personal Data, we will treat the combined information as Personal Data.
4.2.1. Tracking Data and Cookies
Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as “Tracking Data”. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. When you visit any of our Sites, our servers log your computer’s IP address.
4.2.2. Game-Related Information
In order to provide you with efficient services, we need to collect, store and use various information about your activity in our Games. “Game-Related Information” includes your in-game identifier, which for most of our Games is known as “TECHHOME ID”, as well as what is usually referred to as “game statistics”. By “game statistics” we mean information about your Games preferences, progress in the Games, participation and performance in clans, frequency of playing.
4.2.3. Device Information and Geo-Location
In order to fix crashes and other technical issues that may arise while you are installing the Games and using our Services, as well as to make our Services more suitable for you, we collect, store and use information about the device you are using the Services on, including what type of device it is, what hardware and operating system you are using, the device settings, unique device identifiers, and crash data (if any). Whether we collect some or all of this information often depends on what type of device you are using and its settings. You may also install applications collecting and using additional data required for fixing crashes, errors and other technical issues arising during your use of the Services.
To make Services more suitable for you and only upon your permission we can also collect your precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location.
4.2.3. Information required for fraud and violations detection
We may also collect certain data (like IP address, username, etc.) that is required for our detection, investigation and prevention of cheating in the Game and EULA violations. This data, being used only for the purposes of detection, investigation and prevention of frauds and cheating in the Game is deleted six months after its collection, unless the data can be used to prove that cheating has occurred. If the data can be used to prove that cheating or another fraud or EULA violation has occurred, we will further store the data for the establishment, exercise or defence of legal claims during the applicable statute of limitations. Please note that the specific data stored for this purpose may not be disclosed to you or any third parties, since the disclosure will compromise the mechanism through which we detect, investigate and prevent frauds and cheating in the Game, as well as other EULA violations.
4.2.4. Information from publicly available online resources We may use the information made publicly available, e.g. through vk.com, Facebook, Instagram and Twitter, in order to find out your opinion about Games and Services, so that we could take them into account while improving our Services. Such data collection can be carried by TECHHOME independently, or received from our partners making analysis of public sentiments on various issues.
4.2.5. Information from our partners
In some cases, TECHHOME receives your personal data as a data processor, which means that the data is controlled by our partners and we use it only in accordance with their instructions and applicable laws. We use this data in order to fulfil our obligation under the EULA, improve the Servcies, and when processing is required in order to comply with a legal obligation to which we are subject.
Payment partners. When you purchase virtual items, virtual currency, or time-limited premium memberships with your credit card, we may receive from our payment partners and process a part of your credit card number, information about your credit card issuer, as well as your full address for billing purposes;
Co-Promotion Partners. In order to provide you with in-game items and/or in-game currency for participation in various loyalty programs, we may also receive information from our partners, such as telecommunication companies (e.g., Rostelecom), banks (e.g., Alfa-Bank), cashback partners (e.g., Kopikot), travel agencies (e.g. Biletix), and others;
Platforms. We also receive and use your identifiers on other platforms like PlayStation®4, Xbox 360 and Xbox One, App Store, Google Play Store, so that you can play our gGames through these platforms;
Social networks. We have registered certain Games-related group accounts and pages at vk.com, Facebook, Twitter, Reddit, and other social networks to better communicate with our players in case they have questions about the Services, as well as prefer to learn about news about the Services through the social networks. Also, we get information relating to your profiles on social networking sites in order to allow integration with such social networking sites, e.g., your name, avatar, and date of birth, if you link a third party tool with our Services.
5. HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to perform the contract with you according to Article 6(1)(b) of the GDPR. As a user, we will use your Personal Data, unless otherwise prohibited by law, for the following purposes:
to provide you with the Services you request, i.e., to ;allow your installation of the Games, operate the Services and verify and confirm your payments;
to communicate with you about your Account or transactions with us and send you information about features on our Sites or changes to our policies;
to provide support including, but not limited to, product updates, product patches and fixes and other similar communications;
to arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning an offline competition, etc.
5.1. COMMUNICATION PURPOSES
We will use your Personal Data for our legitimate interests according to Article 6(1)(f) of the GDPR to advertise our products and services in accordance with this Policy. Also, if you opt-in, we will send you personalized marketing emails, messages and in-game and web offers about TECHHOME offline events, co-projects of TECHHOME and its partners, as well as about TECHHOME games.
5.2. IN-GAME OFFERS
We will also use the Game-Related Information to send you in-game offers that we believe are most useful to you. To make the offer we first collect Game-Related Information from various players, identify patterns in their behaviour, and create algorithms that identify pools of players following the pattern or particular players who follow the pattern. To those players who actually follow the pattern – we send the in-game offers, which can be personalized (i.e., we want the in-game offer to reach you or a relatively small number of players specifically) or non-personalized (i.e., we want the in-game offer to reach a large number of players following a pattern). We make sure that such offers never have any significant impact on you or our other players.
5.3. SERVICES IMPROVEMENT PURPOSES
We analyse your information to identify how to improve the Services and our operations to make them more suitable and interesting for our players in general. We also may ask you to respond to our Services-related questionnaires, and you always have the choice about whether to respond to them and which information you provide.
5.4. FRAUD AND EULA VIOLATIONS DETECTION
We use the information required for our detection, investigation and prevention of cheating in the Game and violations of EULA and Game Rules and policies only for the purposes of detection, investigation and prevention. If the data can be used to prove that cheating or another fraud or EULA violation has occurred, we will further store the data for the establishment, exercise or defence of legal claims during the applicable statute of limitations.
6. HOW WE SHARE YOUR INFORMATION
For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data with the following categories of third parties:
Payment partners: we share your email address, IP address, information about in-game purchases requested by you at TECHHOME’s web-sites, and other information you provide to us for the purpose of fulfilling your purchase and withdrawal requests with such companies as Adyen BV, PW Inc., PayPal (Europe) Sarl Cie, “Yandex.Money”, NBCO LLC;
Advertising and advertising measurement partners: we share your email, nickname, IP address and other information you provide to us in order to facilitate targeting, delivery, and measurement of online advertising on third-party services, facilitate transmittal of information that may be useful, relevant, or of interest to you, e.g.. allowing you to get rewards for viewing in-Games advertisements with such companies as Emarsys UK Ltd, Unity Technologies APS;
Data storage partners: we store some of your information using third-party data storage services, e.g., while some of your Game-related information is stored using Google Cloud Platform (BigQuery), as well the services of Amazon Web Services, Inc., G-Core Labs S.A.;
Software providers: proper Services rendering requires us to use software solutions of third parties, e.g., for our in-Games questionnaires, including storage of your replies, we use the software of Widgix, LLC dba Survey Gizmo, to provide you with easy access to your game statistics we use software of Mixpanel, Inc.;
Research partners: we may provide access to some of your data, such as your Game statistics, to provide marketing-related and other research. We share anonymous data with our partners unless your personal data is necessary for the requested services or research;
Player Support partners: for some territories and products we engage third parties to provide you with appropriate player support services. Such companies may get access to your personal data, including personal data that you may provide in your player support requests;
Developers of applications based on the Game: we make your nickname and some of your Game statistics available to other players and our partners through Public API. The data can be used for developing and support of the applications created by the Game community, mobile applications. Public API enables us to improve your gaming experience, fulfil potential of our community, and put use of our players’ statistics under our control by creating rules and requirements for their use by other players and community;
Information available to other players: making your nickname and game statistics available to other players through our Services is an important part of making players’ experience more enjoyable. If you are banned in a Game based on other players’ complaints, we may inform them about the ban;
Publicly available information: our Sites may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. Your nickname and game statistics may also become available within Games replays and other videos, which TECHHOME or other players may generate and put online. Please do not include into your nickname any data that can identify you personally;
External moderators and testers: some limited data about you (such as your nickname, content of player support ticket) may become available to third party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Games;
Anti-cheat and anti-fraud companies: we may share the information required for our detection, investigation and prevention of cheating in the Games and EULA violations only for the purposes of detection, investigation and prevention of cheating in the Game. Such partners include ACI Worldwide (EMEA) Ltd., UK;
Logistics partners: to arrange your trips (e.g., as an eSports player) and deliver the prizes you may be entitled to thanks to use of your Services, we can share your post address and other required details with our logistics partners or ask you to share that data with our logistics partners directly;
Third-party websites: you can choose to log into some websites using TECHHOME OpenID. In this case we pass to the websites your nickname and your profile link. Please check our Player Support articles on OpenID for more details and note that TECHHOME does not control further use of this data by third-party websites, i.e., we cannot request their erasure of your data;
Public authorities and auditors: some personal data shall be disclosed to public authorities, e.g., tax and customs authorities, auditors, and other competent parties, in accordance with Union or Member State law;
When your personal data is shared with TECHHOME affiliates and subsidiaries, as well as third parties outside the European Union or the European Economic Area, TECHHOME guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with TECHHOME affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the standard data protection clauses upon your request.
Sharing anonymous information. We also may share anonymous information, i.e. information which does not directly or indirectly disclose your identity, and aggregated information (meaning information about groups and categories of users, including game statistics and behaviour, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
7. YOUR RIGHTS
7.1. OPT-OUT OF DIRECT MARKETING AND RIGHT TO OBJECT
You can manage your subscriptions to direct marketing. Please note that even if you unsubscribe from all our personalized marketing emails, messages, in-game and web- offers, we will still send you some notifications. Also, even after you have unsubscribed from our in-game and web offers, you may still see them within the Games and on some web-sites: that would mean that such offers are shown to everyone or to a very broad audience or to a very broad audience and are not specifically directed to you.
You can opt-out of personalized advertising in mobile applications, including our mobile Games, by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). You can adjust your mobile push notifications in your Android or iOS device settings menu.
Where processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you can use your right to object at any time. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims.
7.2. RIGHT OF ACCESS
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. Normally, we provide the duplicate of the Personal Data retained within 30 (thirty) days upon your request. Once the archive with the Personal Data we retain is ready, you will be able to download in it from our resources. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. We also will not be able to provide you with some Personal Data that you may post or provide using our Services regardless of our request not to provide the Personal Data in this particular field, website, etc.
7.3. RIGHT TO RECTIFICATION
You control which nickname, email, phone number, country, social networks accounts, trusted sites and payment methods we associate with your Account. If they change, please modify the data in the Personal Account directly. Please inform us if any of the Personal Data we retain about you is inaccurate.
7.4. RIGHT TO ERASURE
You have the right to obtain deletion by us of Personal Data concerning you by deleting your Account via our “Account Deletion” tool available in the Account Management tools.
Information we retain. Upon expiry of the suspension period we will delete all Personal Data about you, except for the data that are required for our compliance with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating in the Game and EULA violations. Information you have shared with others (e.g. through in-Games chats, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
You also have the right to lodge a complaint at a supervisory authority.
8. WE CAN CHANGE THIS POLICY
We may change this Policy from time to time for various reasons, such as legal and regulatory changes, changes in industry practices and technological developments that need to be reflected.
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