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PRIVACY POLICY

Last updated 24th of May 2018

 

This Privacy Policy explains what kind of information about you Gaijin Distribution Kft. collects and processes when you use our mobile games “War Conflict”, “Shadows of Kurgansk”, “Star Conflicts Heroes”, “The Abandoned”, and others applications published by Gaijin Distribution Kft. (“Game”/”Games”), the official website of the Games - www.gaijindistribution.com as well as other websites related to Gaijin Distribution Kft. or Games (“Website”/”Websites”). Gaijin Distribution Kft. will hereinafter be referred to as “Gaijin”. The pronouns “we”, “our” and their derivatives also refer to Gaijin Distribution Kft.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE CONTINUING TO USE THE GAME OR THE WEBSITE. BY CONTINUING TO USE THE GAME OR THE WEBSITE YOU WILL BE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.

If after reviewing this Privacy Policy you still have questions or privacy concerns please contact us at privacy@gaijindistribution.com.

 

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 Distribution Kft.

Address: Andrássy út 100, 1062 Budapest, Hungary

E-mail: privacy@gaijindistribution.com

 

2. DATA WE COLLECT ABOUT YOU

2.1. Data you provide us:

2.1.1. Your profile data (i.e., profile photo, username);

2.1.2. Your messages to our support team, chat logs and forum posts;

2.1.3. Your name and e-mail provided when contacting our support team.

2.2. Data we may collect automatically:

2.2.1. User ID generated by us;

2.2.2. Mobile device ID (i.e., device ID, advertising ID, MAC address, IMEI);

2.2.3. IP-address;

2.2.4. Data about your mobile device (operating system, browser type and language, manufacturer, model, screen resolution, interface language);

2.2.5. Profile data and gameplay data;

2.2.6. Traffic source (source from which the Game was installed on your mobile device);

2.2.7. Internet connection data (connection type, type of Internet connection for mobile Internet, name of mobile operator);

2.2.8. General location data (if available, usually the country and the city, without identifying your specific location);

2.2.9. Exact location data (by using GPS, by your consent only);

2.2.10. 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.);

2.2.11. Records of your requests to our support team, other requests send to us in accordance with this Privacy Policy.

2.3. Data we may collect from our partners:

2.3.1. Data we collect when players link third-party services (i.e., Apple Game Center, Google Play, VKontakte, Facebook, Forsquare) with our Games, including your name (nickname), 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);

2.3.4. Data for advertising and analytics purposes, so we can provide you a better service.

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 in game chats and 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 Website - for this purpose we do the following:

(a) operate, administer and support our Games and Website;

(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, Website 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 Website for you (i.e., by storing your preferences and settings);

(g) interact with you (through our support team, by sending push notifications and otherwise, in from of query response, providing you information about games and services);

(e) send legal notices to you within the Games, the Website, or by using available contact information (if any).

(2) To show personalized advertisements - for this purpose our analytics partners (see article 5.2.) and some other partners may track your online behavior and then show you personalized advertisements in the Games as well as in other games and websites. In addition, we may make you special personalized in-game offers based on the data about your use of our Games. For details on your right to opt out of personalized advertisements, 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 profile 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, 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

As a rule, we do not share your user data with anyone and ensure confidentiality of your data. However, in some cases described in this Privacy Policy, we may share your 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.Firebase and Yandex.AppMetrica. 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.Firebase.

The Games use the Google Firebase 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.

5.2.2. Details of using Yandex.AppMetrica.

The Games use Yandex.AppMetrica web analytics provided by Yandex. Yandex.AppMetrica collects some user data from your mobile device to analyze user activity. Information collected does not reveal your identity, but it can help us to improve our Games. Information about your use of our Games collected by Yandex will be transferred to Yandex and stored on Yandex’s server in the EU and the Russian Federation. Yandex will process this information to assess how you use the Games, compile reports for us on our games operation, and provide other services. Yandex processes this information as specified in the Terms of Use of Yandex.AppMetrica - https://tech.yandex.ru/appmetrica/.

5.3. Advertising partners. We may share some impersonal user data necessary for the transfer of advertisements, accounting for the rendered advertising services with our advertising partners.

5.4. Tracking partners. We allow our partners to track the number of impressions, installations, and other indicators of the effectiveness of our ads, and in this respect they have the right to process some of your user data. For instance, we use Facebook and AppsFlyer tracking services. Please have a look at their privacy policies: https://www.appsflyer.com/privacy-policy/, https://www.facebook.com/privacy/explanation.

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, (e) protection from fraud and unfair methods of play.

5.6. Advertisers. We allow third-party companies to place personalized ads in the Games. We do not place or moderate these ads. We may share with these partners some of your user data, including identifiers of your mobile device, your mobile device technical information, information about your use of the Game, as well as other information that our partners may use to show you the personalized ads in the Games. Unity Ads and Fyber Group are one of our advertisers. Unity Ads processes some of your user data in accordance with its privacy policy - https://unity3d.com/legal/privacy-policy. Fyber Group processes some of your user data in accordance with its privacy policy - https://www.fyber.com/legal/privacy-policy/.

5.7. 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 Distribution Kft. 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 Distribution Kft. with another company, respectively, without your additional consent.

5.8. 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.

In the future, we may enter into contracts with other partners, we will make every reasonable effort to update the list of our partners given in this Privacy Policy in a timely manner at least once every six months, or more often in the event of a significant change in our data processing practices.

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 the Game (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 in most cases opt out of receiving push notifications by going to your device “Settings”.

6.2.2. You may opt out of receiving personalized ads in mobile applications by using you advertising ID of your mobile device by going to your device “Settings”. For Apple devices, follow the instructions available at https://support.apple.com/en-us/HT202074 or contact Apple Support. For Android devices, follow the instructions available at https://support.google.com/accounts/answer/2662856?co=GENIE.Platform%3DAndroid&oco=1 or contact Google support.

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. You may opt out of receiving personalized (interest-based) ads (but not ads in general), placed in our Games by our partners, in accordance with article 5.6.

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 the Game settings (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 privacy@gaijindistribution.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 privacy@gaijindistribution.com.

If you believe that your personal data rights have been violated, please let us know at privacy@gaijindistribution.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. 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.

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 privacy@gaijindistribution.com. 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.

 

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.

 

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.

 

10. COOKIES

We and our partners (i.e., advertising partners, analytics partners) may use cookies and other similar technologies (web beacons, pixels, device ID, etc.) to recognize you and/or your device for the purposes of provision our services and personalization of the Games, the Website and related services, for the analysis of your use of our Games and Website, for showing you the personalized ads and prevention of fraud. For more information about cookies and how to disable them, please visit https://www.aboutcookies.org/. In addition, some third-party advertisers can use cookies in their advertising campaigns within our Games and Website. Such cookies are used to collect anonymous behavioral information that advertisers use to provide personalized ads within and outside of our Games and the Website. To disable this feature, go to http://optout.aboutads.info/, and follow the steps described there. In addition, you can disable these and other cookies in your browser settings. However, please note that some of the functions of the Games, the Website and the related services may not be available to you or may work improperly in the event that you disable some cookies that are not related to the personalization of ads, while in general the Games and the Website will remain accessible to you.

 

11. UPDATES TO THIS PRIVACY POLICY

The current version of this Privacy Policy is available at https://gaijindistribution.com/en/pp/.

We may change this Privacy Policy at any time. Any updates to this Privacy Policy come into effect from the moment of publication of the updated version of the Privacy Policy at https://gaijindistribution.com/en/pp/, unless another effective date is specified in the text of the updated version of the Privacy Policy.

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