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PERSONAL DATA PROCESSING INFORMATION
1. GAME
1.1. The company Delta VR Ventures s.r.o., ID No. 19621728, with registered office at Chvalská 718/10, Hloubětín 198 00 Prague 9, Czech Republic registered in the Commercial Register of the Municipal Court in Prague, file No. C 389336, under Czech laws ("Controller", "Company" or "We") created games, application and other software products ("Game").1.2. To start playing the Game, you must first agree to the End User License Agreement ("EULA") and to register into third party account ("Account").
2. PROCESSING OF PERSONAL DATA
2.1. If you use / play the Game, the Company becomes the controller of your personal data within the meaning of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("Regulation").3. CATEGORIES OF PERSONAL DATA
3.1. If you are using the Game, we might process the following categories of personal data:3.1.1. Identification data: name, surname, date of birth.
3.1.2. Electronic contact details: e-mail address, nickname in the Account, password for the Account, Telegram ID, Telegram nickname, Telegram name.
3.1.3. Other data: avatar, gender, user ID under which you are registered, 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 or Magic Madness web site chat you provide us with.
3.1.4. Technical data: data concerning your use of the Game (how successfully you play the Game, your progress in the Game etc.).
3.1.5. 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, performance data and other statistical data.
3.1.2. Electronic contact details: e-mail address, nickname in the Account, password for the Account, Telegram ID, Telegram nickname, Telegram name.
3.1.3. Other data: avatar, gender, user ID under which you are registered, 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 or Magic Madness web site chat you provide us with.
3.1.4. Technical data: data concerning your use of the Game (how successfully you play the Game, your progress in the Game etc.).
3.1.5. 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, performance data and other statistical data.
4. LEGAL TITLE AND PURPOSE OF PROCESSING
We process personal data for the following reasons:4.1. Processing of personal data based on applicable laws
4.1.1. We process your personal data based on applicable laws which apply to our business activities.
4.1.2. If you buy the Game from us, we might process your personal data in compliance with law No. 563/1991 Coll., Accounting Act, law No. 235/2004 Coll., Value Added Tax Act and law No. 586/1992 Coll., Income Tax Act, for purposes of carrying out our obligations arising out of mentioned laws, particularly keeping records of all purchases and payments.
4.1.3. If you buy the Game from us, we also might process your personal data in compliance with law No. 634/1992 Coll., Consumer Protection Act for purposes of carrying out our obligations arising out of this law and securing your rights.
4.2. Performance of contractual obligations4.1.2. If you buy the Game from us, we might process your personal data in compliance with law No. 563/1991 Coll., Accounting Act, law No. 235/2004 Coll., Value Added Tax Act and law No. 586/1992 Coll., Income Tax Act, for purposes of carrying out our obligations arising out of mentioned laws, particularly keeping records of all purchases and payments.
4.1.3. If you buy the Game from us, we also might process your personal data in compliance with law No. 634/1992 Coll., Consumer Protection Act for purposes of carrying out our obligations arising out of this law and securing your rights.
4.2.1. The date of birth is processed to verify you are old enough to play the Game according to the EULA.
4.2.2. Electronic contact details are processed to provide you with the Game.
4.2.3. 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.
4.2.4. Technical data are processed to make the Game functional.
4.2.5. 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.).
4.3. Processing of personal data based on legitimate interest4.2.2. Electronic contact details are processed to provide you with the Game.
4.2.3. 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.
4.2.4. Technical data are processed to make the Game functional.
4.2.5. 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.).
4.3.1. 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.
4.3.2. Some of the statistical data can be used to prove that cheating or another fraud or EULA violation has occurred.
4.3.3. We can process your nickname and your progress in the Game or results in the Game to create leaderboards of players' success.
4.3.4. We might process your contact details to offer you similar goods or services to the Game or products bought in the Game. We can also send you information about news from our company, Christmas or birthday wishes and other information related to our brand and our products.
4.3.5. We might process technical data to offer you services or Game items in accordance with the progress or strategy in the Game.
4.4. Consent4.3.2. Some of the statistical data can be used to prove that cheating or another fraud or EULA violation has occurred.
4.3.3. We can process your nickname and your progress in the Game or results in the Game to create leaderboards of players' success.
4.3.4. We might process your contact details to offer you similar goods or services to the Game or products bought in the Game. We can also send you information about news from our company, Christmas or birthday wishes and other information related to our brand and our products.
4.3.5. We might process technical data to offer you services or Game items in accordance with the progress or strategy in the Game.
4.4.1. When using the Game, we might ask you, if you want us to process some of your data to use them for:
4.4.2. When using the Game, we might ask you, if you want us to process some of your data to use them for:
4.4.2. When using the Game, we might ask you, if you want us to process some of your data to use them for:
- marketing purposes: such as sending marketing communications, newsletters, or personalized offers (that do not fall within our legitimate interest).
- content personalization: to use data about your preferences and behavior to tailor Game content, recommend new features, or offer a personalized gaming experience (that does not fall within our legitimate interest).
5. PROCESSORS, RECIPIENTS, AND TRANSFER OF PERSONAL DATA
5.1. 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:5.1.1. payment partners,
5.1.2. software and IT service providers (e.g. Google, Microsoft),
5.1.3. marketing service providers,
5.1.4. legal service providers.
5.2. 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.5.1.2. software and IT service providers (e.g. Google, Microsoft),
5.1.3. marketing service providers,
5.1.4. legal service providers.
6. STORAGE TIME
6.1. 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:6.1.1. 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.
6.1.2. 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.
6.1.3. 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.
6.1.4. 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.
6.1.2. 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.
6.1.3. 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.
6.1.4. 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.
7. YOUR RIGHTS
7.1. In particular, you have the following rights in relation to your personal data:7.1.1. 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.
7.1.2. 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.
7.1.3. 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.
7.1.4. 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.
7.1.5. 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.
7.1.6. Right to withdraw the consent to process your personal data. Where we process your personal data based on your consent You can withdraw such consent at any time by sending us a request at [email protected]
7.1.7. 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.
7.1.8. 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.
7.1.2. 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.
7.1.3. 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.
7.1.4. 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.
7.1.5. 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.
7.1.6. Right to withdraw the consent to process your personal data. Where we process your personal data based on your consent You can withdraw such consent at any time by sending us a request at [email protected]
7.1.7. 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.
7.1.8. 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.
8. THE SOURCES OF YOUR PERSONAL DATA
8.1. We acquire your personal data from the following sources:8.1.1. Directly from you during your registration to Account, using our other services where necessary, by filling forms during your use of the Game or by direct communication with you.
8.1.2. From monitoring of the use of the Game.
8.1.2. From monitoring of the use of the Game.
9. CONTACT
9.1. If you want to contact us, make a complaint, ask us about anything related to the processing of your personal data or tell us that you do not want us to process your personal data, you can use the following contact details:Delta VR Ventures s.r.o.
Chvalská 718/10, 198 00 Prague 9, Hloubětín, Czech Republic
E-mail: [email protected]
10. DATA SECURITY
10.1. In order to secure your data against unauthorized or accidental disclosure, we apply reasonable and appropriate technical and organizational measures, which are continuously updated. The technical measures consist of the deployment of technologies preventing unauthorised access to the data by third parties. Organizational measures are a set of rules of conduct of our coworkers and are part of our internal regulations, which are considered confidential for security reasons. If our servers are located in a data centre operated by a third party, we ensure that the technical and organisational measures are also implemented at this provider.11. OTHER AND FINAL PROVISIONS
11.1. If you refuse to provide personal data necessary for the above purposes, we may not be able to provide you with our service.11.2. Our company might carry out personal data processing activities that involve profiling (an offer of goods or services that is based on a player's progress or strategy in the Game).
11.3. We process personal data via software, so the processing is at least partially automated.