Updated 18 August 2021
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 websites owned or operated by Redhill Games:
Redhill Games Oy
5 Lonnrotinkatu, 00120 Helsinki, Finland
2. WHY WE COLLECT AND PROCESS YOUR PERSONAL DATA
We collect and process your personal data for the following purposes:
- when it is necessary for the performance of a contract with you;
- when it is necessary for compliance with a legal obligation to which we are subject;
- when it is necessary of the purposes of our legitimate interests, except where such interests are overridden by your legitimate interests and rights; or
- when you have given a consent to it.
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. INFORMATION WE COLLECT AND HOW WE USE IT
In relation to your use of our Game and Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g. through our website’s technology or through our partners and subcontractors).
3.1. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data in relation to you interaction with our Game for the purpose of providing use said Game service and to further develop the Game and our other Services. In addition to Game related data we also collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information.
3.1.1 User ID and User Name
In order to access our Game you are required to set up an Account and create an user id with our distribution partner (e.g. Steam or Stadia) (“User ID”) and use that User ID to log into our Game. In addition, you are required to choose an in-Game name when first logging into our Game (“User Name”).
Your User ID is used to identify your user account with our distribution partner and keep your player progression in our Game. You User Name is used as you public reference within our Game without directly exposing your Personal Data.
3.1.2 Content Data
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 Redhill Games-related forums owned or operated by Redhill Games (“Forums”), on the pages of social network groups operated by Redhill Games, and on the sites;
- Information that you provide to us to become a participant of UX tests, alpha-tests, super tests; and
- Information that you provide to us offering your partnership or services.
3.1.3 Your use of our Game
In order to provide you with services, we need to collect, store and use various information about your activity in our Game. Such information includes your User ID and User Name, as well as what is usually referred to as “game statistics” such as information about your in-game preferences, progress in the games, playtime, the geographical location you are accessing the game from as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.
3.2. INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our Sites and social media pages. 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.
3.2.1. 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 our site, our servers log your computer’s IP address.
How to delete cookies and opt out of targeted advertising and analytics
If you wish to limit behaviorally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out will take effect.
For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).
For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies (e.g. https://support.google.com/chrome/answer/95647 for Chrome),
and by visiting the following sites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu
3.2.2. Information from publicly available online resources
We may use the information made publicly available, e.g. through YouTube, vk.com, Facebook, Instagram and Twitter, in order to find out your opinion about the Company and Services, so that we could take them into account while improving our Services. Such data collection can be carried by Redhill Games independently, or received from our partners making analysis of public sentiments on various issues.
3.2.3. Information from our partners
In some cases, Redhill Games 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 Services, and when processing is required in order to comply with a legal obligation to which we are subject.
Social networks.We have registered certain Redhill Games-related accounts and pages at Facebook, Twitter, Instagram, LinkedIn, and other social networks to better communicate with our partners, candidates and 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.
4. HOW LONG WE STORE THE DATA
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
5. WHO HAS ACCESS TO THE DATA
Except as described below, we do not share, sell or otherwise disclose your Personal Data to third parties:
Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.
Third-party plugins. When third-party technologies or social tools are integrated into our Game and Services, those third parties may collect information about your use of our Game or Services.
Public authorities and auditors: some Personal Data may 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 Redhill Games affiliates and subsidiaries, as well as third parties outside the European Union or the European Economic Area, Redhill Games 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 Redhill Games 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.
6. YOUR RIGHTS AND CONTROL MECHANISMS
The GDPR in European Economic Area and other data protection laws in other territories grant their residents certain rights in relation to their Personal Data.
To exercise your data protection rights send us your request at firstname.lastname@example.org (data erasure and objection to data processing).
According to the GDPR, you have the following data protection rights:
6.1. 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.
6.2 RIGHT TO RECTIFICATION
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided by sending us your request at email@example.com.
6.3 RIGHT TO ERASURE
You have the right to obtain deletion of your Personal Data if: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw your consent on which the processing is based, and where there is no other legal ground for the processing (provided that the processing was based on your consent); or (iii) if you object to the processing of your Personal Data there are no overriding legitimate grounds for the processing. You can request the deletion of your Personal Data by sending us your request at firstname.lastname@example.org.
6.4 RIGHT TO OBJECT
When our processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to this processing by sending us your request at email@example.com. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.
6.5 RIGHT TO RESTRICTION OF PROCESSING OF YOUR PERSONAL DATA
You have the right to obtain restriction of processing of your Personal Data under the conditions set out in Article 18 of the GDPR.
6.6 RIGHT TO PERSONAL DATA PORTABILITY
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in article 20 of the GDPR by sending us your request at firstname.lastname@example.org.
7 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 unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
8. WE CAN CHANGE THIS POLICY