Last updated on July 6th, 2018
1. General provisions.
Elyland Investment Company Limited (hereafter referred to as "We" or "Company") takes all the necessary measures to process and protect the personal data of players of the game "Clash & GO: AR Strategy" (hereafter referred to as "Game").
Please note that We may combine the information We collect from You independently with the data that You provide Us with.
Capitalized terms that are used in this document signify the same concepts as those in the EULA.
2. Information on the person (controller) who controls the processing of players' personal and other data in the Game:
Elyland Investment Company Limited, HE 266867, address: 7 Florinis, Greg Tower, 2nd floor, 1065, Nicosia, Cyprus. You can contact Us via firstname.lastname@example.org.
3. What do we mean under personal identifiable information or personal data?
Personal data or personal identifiable information means any information relating to an identified or identifiable natural person. The definition of personal data now encompasses not only natural person's explicit identifiers like name or address, but also any online identifiers (for example, IP address, Your device ID etc.) together with other personal data.
4. Categories of information We collect.
We collect, process, or use the following categories of personal and other data:
- Your nickname (username in the Game), email address;
- Information on Your whereabouts, speed and route in the Game while playing it;
- Information about Your in-Game transactions (transaction ID, amount, currency and time of transaction);
- Your identifiers in social networks and age-related interval, if You log in the Game using such networks, and demographic data (gender);
- Your name, address, other data that you have provided while contacting Us via telephone, email or in any other way, especially using the contact forms in the Game or on the Website of the Game;
Technical information such as Your IP address, which is used to connect Your device to the internet, information identifying Your device, Google advertising ID (or advertising ID for users of iOS), Your internet browser data, the operating system on Your device, the trademark and model of Your device, the time settings, the time of logging into the Game, information regarding Your usage of the Game (what Game sections You visit, how long the game process takes etc).
Data that You have sent to Us through an online survey or support ticket.
Payment information: We do not collect by Ourselves any payment data or personal payment data. Payments that You may make for the purpose of purchasing Additional Services or objects in the Game, will be processed by the payment processor according to its confidentiality and security policy. However, Our payment services providers disclose to Us some categories of users data related to their payments, in particular, amount and currency of transaction, transaction ID etc.
5. Children's data
6. When do We collect information?
We collect information about You when You register in the Game, log into the Game, play, surf the Website of the Game, subscribe to a newsletter, fill out a form or enter information on the Website of the Game, contact Us, respond to a survey or marketing communication, or use certain other Game features.
We may receive information about You from third parties, for example, if You decide to log into the Game using any of Your accounts on other platforms (Google, Facebook). We may combine such information received from third parties with the data that You provided Yourself or that has been collected automatically. All kinds of information will be processed according to this Policy.
If You do not ask Us to delete certain data beforehand, We will store it for the period indicated by law, or necessary for the realization of the purposes for which We have collected it. In any case We may retain your personal information so long as Your in-Game account exist.
We collect and process Your personal and other data in order to:
- Fulfill Our duties and exercise Our rights as specified in EULA;
- Provide You with the services in the Game and access to the Game that You expect from Us and customer support per Your request;
- Provide You with information about the Game and the services in the Game, e.g. notifications about changes in the Game, and/or rules that regulate the process of the Game;
- Improve the Game and services it offers, including technical part of the Game, making sure players abide by the Game Rules, ensuring players' safety in the Game;
- Process transactions and send notices about Your transactions;
- Administer the Website of the Game and the application, performing internal operations, including the detection and fixing of any bugs on the Website of the Game or the application; data analysis, testing, statistics and control purposes, using anonymous or pseudonymized personal data;
- Resolve disputes and troubleshoot problems;
- Prevent potentially prohibited or illegal activities, and enforce Our EULA, Game Rules or other legal documents;
- Ensure the security of Our Game and the Website;
Please notice that We may use information on Your whereabouts, route and speed for the purposes of improving the Game, protecting it from prohibited methods of playing, as well as ensure the logic of the game process.
Beyond these purposes, We process Your data only if You have granted express consent for its stated purposes (for example, market to You specifically, such as through email remarketing and web retargeting).
8. What is the legal basis for processing Your personal information?
We are committed to protecting Your privacy and handling Your data in an open and transparent manner and as such We process Your personal data for one or more of the following reasons:
For the performance of a contract. We process personal data in order to offer services based on contracts (EULA) with Our customers but also to be able to complete the procedure so as to enter into a contract with prospective players. The EULA terms and conditions provide more details of the relevant purposes.
For compliance with a legal obligation. There are a number of legal obligations emanating from the relevant laws to which We are subject as well as statutory requirements (i.e. financial reporting, paying taxes). Such obligations and requirements impose on Us necessary personal data processing activities for compliance with, for example, court orders, tax law or other reporting obligations.
For the purposes of safeguarding legitimate interests. We process personal data so as to safeguard the legitimate interests pursued by Us or by a third party. A legitimate interest is when we have a business or commercial reason to use Your information. But even then, it must not unfairly go against what is right and best for You. Examples of such processing activities include: initiating legal claims and preparing our defense in litigation procedures: measures to manage business and for further developing Our Game and related services.
You have provided your consent. Provided that You have given Us Your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of Your revocation will not be affected.
9. Transfer of information to third parties.
Services providers. We may use third party companies and individuals for the purpose of developing and supporting the Game and Website, providing access to the Game on Our behalf and services in it (e.g., without restriction, hosting and operating the Website, database management, web analytics pertaining to the processing of payments, detecting fraudulent activities, and improving the Game's Website and application, or helping Us in analysing the practices of Your usage of the Game). Such third parties may have access to Your personal data within the context of performing such work on Our behalf. These processors may be located outside the European Union. Please note that the Company grants access to any information under the condition that the third party ensures the safety of the information to which it may have access according to the data protection laws and the GDPR (The EU General Data Protection Regulation).
In particular, We work with (or may work with in the future) network advertisers, advertising agencies, providers of analytics services and other providers, which provide Us with information regarding the traffic on the Website and Game application, including the pages visited and actions taken by a player; support Our advertisements on other websites, mobile applications and other places on the internet; provide Us with information on the usage of the Game and the effectiveness of Our advertisements. Our service providers may collect certain information about Your visits and actions in the Game, as well as other websites or services. They may also install and gain access to their own tracking technologies on Your technical device (including cookies and web beacons) and may use this information to show You targeted advertisements, provided You give Your consent to these activities.
We may also share Your personal information with other entities of Our corporate group. Such disclosure is regulated by Our internal corporate privacy policies.
It must be noted that We may disclose information about You for any of the reasons set out hereinabove, or if We are legally required to do so, or if We are authorized under Our contractual and statutory obligations, or if You have given Your consent to do so. All data processors appointed by Us to process customer data on Our behalf are bound by contract to comply with the GDPR provisions.
Under the circumstances referred to above, recipients of personal data may be, for example: supervisory and other regulatory and public authorities; external consultants, financial and business advisors; auditors and accountants; marketing operators; card payment processing companies; file storage companies, archiving and/or records management companies, cloud storage companies; companies who assist Us with the effective provision of Our services to You by offering technological expertise, solutions and support; website and advertising agencies.
Our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.
We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose Your personal information to a regulatory or law enforcement agency if We believe it to be necessary to protect the rights, property, or personal safety of Our Company, its customers or any third party.
10. Cross-border data transmission.
Your personal data may be stored on servers that are located beyond the borders of Your country of origin or residence. We take all technical and organizational measures to ensure the security and safety of any of Your personal data that may be stored and processed outside of Your local jurisdiction. Personal data of the EU residents is kept within EU territory.
11. Changing or deleting Personal data or other information on a player, and refusal to provide such data.
If You wish to find out what information about You is being stored, You may do so by sending Us a request at this email: email@example.com. You can also send Us a request to delete or change Your personal data. Please note that in the case of deletion of data, some or all of the Game's functions may become unavailable to You.
At Your request, We will delete Your personal data and will make a commercially reasonable effort to delete any other information related to You. However, certain data will be stored on Our servers even after the deletion of Your personal data. For example, some personally-non-identifiable information related to You may be stored in Our archives for the purposes of administration. Besides, the requirement of information deletion is conditioned by the need of complying of legal obligations and resolving possible disputes. You should also understand that it is not always technically possible to completely remove certain information from Our databases.
Additionally, We will not delete any information that You Yourself have posted publicly in the relevant sections of the Game. Please note that neither You nor the Company can delete all copies of any information that has been previously transmitted to other persons in the Game.
12. How do We protect Your information?
Our servers and other devices as well as software used in the Game and Website are scanned on a regular basis for security holes and known vulnerabilities in order to make Your user experience as safe as possible.
We use regular malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We provide training to Our employees on data protection best practices and require them to enter into a confidentiality agreement. In addition, all personal information You supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when You interact with the Game, enter, submit, or access Your information to maintain the safety of Your personal information. However, while We use all reasonable efforts to protect Your personal information, We cannot guarantee the absolute security of Your data submitted through Our application and Website.
13. Do We use "cookies"?
Yes. When You use The Game or You visit the Website, Our system automatically collects information about Your visit, such as Your browser type, operation system You use, screen dimension and Your IP address.
Such information is typically collected using web cookies, web or email pixels (also known as beacons), embedded hyperlinks, and similar tools. Popular browsers can generally be set to disable or delete individual cookies. See below for the types of cookies We use and their respective purposes.
Required Cookies: enable the navigation and basic functionality of the application and the website, e.g., access to protected areas of the websites.
Functional Cookies: allow Us to analyze Your application and Website usage and your selections (e.g. your login name, language, or region), so We can save these settings and offer you a more personalized experience.
Our application and Website store two types of cookies (identifiers of session and of server) that are required for the navigation and usage of them. Without them the application and Website will not function properly.
- Help remember and process Your choices in Your account.
- Understand and save Your preferences for future visits.
You can choose to have Your device warn You each time a cookie is being sent, or You can choose to turn off all cookies. You do this through Your browser settings. Since browser is a little different, look at Your browser's help menu to learn the correct way to modify Your cookies. If you turn cookies off, some of the features that make your site experience more efficient may not function properly.
14. Contact details
If You have any questions concerning the procedures We use to process Your information, or information related to You in the Game, kindly submit them at the following email: firstname.lastname@example.org or via the contact form on the Game's Website.