CATEGORIES OF PERSONAL DATA
If you have purchased the Game, we might process the following categories of personal data:
- Identification data: name, surname, date of birth.
- Electronic contact details: e-mail address, nickname, password.
- Other data: avatar, gender, fengshui element, user ID under which you are registered, Victoria VR World plot number if you have purchased it, e-wallet address, information you provided to us when participating in contests, loyalty programs, or surveys or when you request information or support from us, and other information in your Account.
- Technical data: data concerning your use of the Game (how successfully you play the Game, your progress in the Game etc.).
- Statistical data: data about your device and browser; IP addresses, information about login times to the Game, usage data, demographic information, geographic, geo-location information.
LEGAL TITLE AND PURPOSE OF PROCESSING
We process personal data for the following reasons:
Performance of contractual and legal obligations
- We process the name and surname so that we can issue an invoice for the purchase of the Game in accordance with laws.
- The date of birth is processed to verify you are more than 18 years old.
- The login nickname, email address and password are processed in order to allow you to log into the Account and, if necessary, for to restore access.
- We also process the date of birth and gender so that we can determine which element (earth, wood, water, metal or fire) corresponds to your person in traditional Chinese feng-shui teachings. Based on this analysis, the content in the Game is then adjusted and personalized. If you do not want us to process your gender, you can fill in your element into your Account.
- The address of the electronic wallet is processed in order to pay the virtual asset to the electronic wallet in the context of providing benefits to the player (e.g. payment of a reward or prize in the contest, etc.).
- Technical data are processed to make the Game functional.
- We process other data that you voluntarily provided to us to provide you with the respective services you requested (having more information in Account, support request etc.).
Processing of personal data based on legitimate interest
- We process statistical data in order to prevent misuse of the Game, to ensure the functioning of the Game and improving the Game. The statistical data are processed in pseudonymised form, so that nobody except for us is able to match the data to the player. This processing is based on our legitimate interest, which is the continuous improvement of the Game. You have the right to object to this processing in the manner described below.
- Some of the statistical data can be used to prove that cheating or another fraud or EULA violation has occurred.
- We can process your nickname and your progress in the Game or results in the Game to create leaderboards of players' success.
PROCESSORS, RECIPIENTS AND TRANSFER OF PERSONAL DATA
For the effective operation of the Game and our company, we have contracts with other service providers to whom we may pass your personal data for processing. In particular, the following may process your personal data:
- payment partners,
- software and IT service providers (e.g. Google, Microsoft),
- marketing service providers,
- legal service providers.
We process your personal data exclusively in European Union countries. Outside of the European Union, we might process your personal data only if it is necessary for the performance of our contractual or legal obligations.
STORAGE TIME
We process personal data only for the time necessary to fulfil the purpose of processing or for the time required by law. The storage period varies depending on the legal title of the personal data processing:
- If the legal basis for the processing of personal data is the performance of contractual obligations, we process personal data for the duration of EULA and then 4 years after the EULA is terminated or for period prescribed by or in accordance with applicable law.
- If the legal basis for the processing of personal data is the fulfilment of our legal obligations, we process personal data for the period of time required by law.
- If the legal basis for the processing of personal data is our legitimate interest, we process personal data for the duration of the legitimate interest, or until you notify us that you do not wish us to process the personal data further and then 4 years after the EULA is terminated or for period prescribed by or in accordance with applicable law.
- If your consent is the legal basis for the processing of your personal data, we will process your personal data for no longer than the duration of your consent.
YOUR RIGHTS
In particular, you have the following rights in relation to your personal data:
- Right of access to personal data - you can contact us at any time to ask if we are processing your personal data and, if so, to request further information about this processing.
- The right to correct or supplement personal data - if your personal data changes during the processing or if you feel that the data we process is incorrect, please contact us.
- Right to request restriction of processing - in the cases referred to in Article 18 of the Regulation, you have the right to request restriction of the processing of your personal data.
- Right to erasure of personal data - in the cases referred to in Article 17 of the Regulation, you have the right to request that we erase personal data concerning you without undue delay.
- Right to request data transfer - under the conditions set out in Article 20 of the Regulation, you have the right to ask us to transfer your personal data to a third party.
- Right to object - where we process your personal data on the basis of our legitimate interest, you have the right to object to such processing at any time.
- Right to lodge a complaint - if you have any doubts about our compliance with our obligations related to the processing of personal data, you have the right to lodge a complaint with the data protection regulator in your jurisdiction.