FULL POLICY

A. Terms related to the process of assessment of personal data

Please, get acquainted with basic terms listed on this document, which can be useful to you for the better understanding of this document.

Personal data – any information that relates to the identified and identifiable individual, e. g. name, surname, date of birth, telephone number, e-mail address, user ID, IP address, etc.,

Affected person / Customer – an individual, to which the personal data are related,

Processing of personal data – an operation or set of the operations with personal data, e. g. collecting, recording, organizing, storing, changing, using, providing to third parties or deleting,

Controller / Service provider - an individual or legal person, which determines the purpose and ways related to the processing of your personal data; this competence can be transferred to the intermediary,

Intermediary – an individual or legal person, a public authority, an agency or other subject, which processes the personal data for the controller and in his name,

Purpose – a reason, why personal data are being processed by the controller,

Special categories of personal data – a sensitive personal information, which is defined by its specific character, e. g. health or biometric data to identify the person,

Authorized (legitimate) interest – an interest of controller or any other subject that results in the need to process the personal data, if it prevails over the interest of the affected person/customer,

Profiling – any automated processing of personal data, which consists of the use of personal data to evaluate certain personal aspects of the affected person/customer,

Recipient - an individual, legal person, public authority or any other subject, to whom are personal data provided.

 

B. Who is the controller of your personal data?

The controller of your personal data is PIXEL FEDERATION, s. r. o. with registered residence: Einsteinova 19, Bratislava 851 01, Slovakia, IČO: 36 816 388, registered in the Commercial Register of the District Court Bratislava I, section: Sro, insertion no. 47333/B (thereinafter in text referred to as ”Company“). The Company determines the purpose and ways of the processing of your personal data.

Basic information about Company: Einsteinova 19, 851 01 Bratislava, Slovakia.

For questions concerning the processing of your personal data by the Company feel free to contact us via the [email protected] or [email protected] email address or by writing at PIXEL FEDERATION, s. r. o., Einsteinova 19, Bratislava 851 01, Slovakia.

 

C. Which personal data are we processing?

The Company collects and processes personal data that is necessary to provide you with products and services or, where appropriate, to protect itself and its legitimate interests. The Company processes primarily the next necessary categories of personal data about its customers (Players):

• A. Identifiers: name, surname, age, gender, e-mail address, unique identifier of a player (User ID)

• B. Internet or other similar network activity: Access history and information on your interaction with the Games, IP address, Cookies files, in certain situations also your Facebook friends and other traffic data (IP address, device model, architecture of CPU, version OS, etc.)

• C. Geolocation data: country

• D. Information you provide: the information you voluntarily provide to sign up for email alerts, use social features like forums or chat, register for early access to our games, use our developer tools (including to create and publish games and other content), complete surveys, or contact us through players support requests or customer service.

The listed are also the categories of personal information that Company collected from its customers within the last twelve (12) months.

 

D. From which source are we collecting your personal data?

The Company collects your personal data in particular from you, especially when accepting the mutual (contractual) agreement about the software use (EULA) or completing surveys, or contacting us through players support requests or customer service. Your personal data can be also collected from other subjects – third parties, e. g. Facebook, Google, Apple, Amazon, Steam, Samsung, WizQ, however only on the basis of your personal authorization provided to these subjects in order to grant your data to the Company.

 

E. Which are the main purposes for processing of your personal data?

For the reason of concluding and fulfilling the contract

Due to the process of conclusion and fulfillment of the contract Company processes your personal data in order of providing an access to the software (Games) of the Company for the user (Player), in order of providing the player support and improving the quality of the services provided by the Company necessary to the rightful function through updates and enhancements, the enhancement of the game surrounding and providing of new functionalities. For this purpose, Company may follow your interactions with Company, as well as to monitor different areas, in which you are interested in, and use your information to personalize our communication with you, including offering in-game surveys. The collected data can be also used as for the purposes of optimization and improvement of the content of services provided to you by the Company as part of the software and in order to detect potential malfunctions and mistakes (errors).

Collected and processed data by Company may be also processed in order to compiling and publishing purposes of general statistical reports to extend and customize of services provided to players, appealing to their preferences. These data do not contain information about the content which could by any way lead to identification of random individual.

Data collected by the Company for designed purposes are being processed on the legal basis of the contractual agreement between the Company and end users – Players – in form of defined licensing terms and agreements about the use of products and services provided by the Company (EULA).

EULA is a contract in accordance with article 6, point 1, letter b) GDPR for the purposes of the determination of legal basis in the operation of processing the personal data.

For the needs of above defined purposes Company processes personal data mentioned in Section C of this Policy, as well as following personal data of the players:

• Registration and authentication of the Facebook account

Data being collected and processed: generally accessible data of Facebook profile, e-mail address, Facebook Friend List (optional), other traffic data,

• Registration and authentication via Apple, Google, Amazon, Steam, Samsung, WizQ

Data being collected and processed: e-mail address and other traffic data

• Direct registration

Data being collected and processed: e-mail address and other traffic data

For the reasons of direct marketing

Under the conditions of its software (game) the Company also uses the functionality of so-called “banners”, through which the player is offered “gems” (a specific kind of payment under the conditions of each single game). This menu is displayed to the players while using software (playing game) as one of the options within the game settings or menu of the game. The player can through these menus purchase additional options, extensions, accessories or any other functionalities within the terms of a specific game.

Based on an analogical advance, various limited offers (so called “premium items”) are being promoted in order to purchase the special edition of the particular element under the conditions of software.

These activities represent the form of direct marketing used by Company (in the relation to aforementioned regulations), that is oriented at specific players and address their potential needs.

The Company implements these activities only under the conditions of the software (game) itself. The use of these activities in any way leads players to the process of purchase, nor does them limit in common use of the game.

According to GDPR, the legal basis for processing of your personal data in terms of this form of marketing is to legitimate interest of the Company in accordance with article 6, point 1, letter f) and in accordance with section 47 of the GDPR.

In terms of the direct marketing’s realization necessaries Company processed the following personal data of players:

• e-mail address

• User ID

• IP address

 

F. To whom can be your personal data provided?

We process your personal data to their fullest possible extent internally within the Company. Your personal data are being provided to other subjects only when it’s necessary to achieve the purpose of processing.

We do not sell your personal data to other businesses. Your personal data might be in some cases disclosed to and processed by our intermediaries for a business purpose (see below), however personal data are in those cases not shared for monetary or other valuable consideration.

In the preceding twelve (12) months, we have not sold personal data. Our policy is that we do not and will not sell personal data of our customers (Players).

Intermediaries

Company cooperates in the case of some activities with external subjects, which process personal data under the name of the Company (thereinafter “Intermediaries”). Intermediaries process personal data always on the basis of a contract between the Company and intermediary. Current company intermediaries are:

• Amazon Web Services (AWS) (Amazon)

• Infrastructure support (Labyrinth Labs s.r.o., SPECIT, s.r.o., Lightstorm, s.r.o.)

• Payment portals (Facebook, Google, Apple, Amazon, PayPal, Skrill, Paysafecard, Klarna, Sofort, WizQ, Samsung)

• Customer support (Freshdesk)

The purpose of intermediaries’ services is to collect, store and provide data, that are necessary for the basic and distributed operation of provided services by Company within the offered software, as well as providing of the basic infrastructure for the operation of specific functionalities and software components.

In the preceding twelve (12) months, we have disclosed the following categories of personal information to our intermediaries for the business purposes:

• A. Identifiers

• F. Internet or other similar network activity

• G. Geolocation data

Public authorities

Your personal data can be provided to public authorities in case of imposition by law or this advance is necessary for the fulfillment of law’s obligations. Public authorities include courts and authorities involved in criminal investigation, etc.

 

G. Where are your personal data being processed?

Your personal data are being processed on servers within the so-called cloud services, provided through third parties on the basis of a contract between the Company and particular third party. These companies are from the point of view of processing the personal data perceived as an intermediary.

 

 

H. How long do we keep your personal data in evidence?

Company processes your personal data for as long as it’s necessary for the duration of an EULA’s contractual relations.

Company applies the principle of minimalization, which means that after the duration of processing your personal data expires, the personal data will be anonymized or deleted from databases and information systems of the Company, at the latest 10 years after the termination of a contractual obligation of EULA.

 

I. Profiling and the process of an automated decision

Company doesn’t implement in relation to you and your personal data an automatic individualized decision-making including profiling, that could cause legal effects on your person.

 

J. Your rights related to processing of your personal data

You have the following rights in relation to the processing of your personal data:

• Access to personal data

You have the right to request information on whether we process personal data about you as well as to request access to this personal data. You have the right to know why we collect the personal data and how we process it, what kind of personal data we process, which organizations receive the personal data and how the personal data is stored.

In case you are California resident, you have the right that we disclose to you (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the specific pieces of personal information we collected about you; (iii) the business or commercial purpose for collecting personal information about you; and (iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months.

• Objection to the processing

You have right to object to the processing of your personal data in case the processing is being carried due to the legitimate interest of the Company. In case Company won’t exhibit that there exist necessary and legitimate reasons for processing, which prevail over your own interests, rights and freedom, or reasons for demonstration, applying or defense of the law requirements, Company will end processing of personal data based on your objection and without undue delay.

Where processing is based on consent, you have the right to withdraw your given consent for Company’s use of your personal data at any time. The withdrawal of the approval does not have any effect on the legitimacy of the processing before it was taken back. You always have the right to object to our processing of your personal data for direct marketing purposes.

• Correction of personal data

You have right to demand correction of inaccurate or incomplete personal data, limitation of our processing and completion of incomplete personal data. Company is obligated to correct or complete your personal data without undue delay, always based on available technical options.

• Deletion of personal data

You have the right to demand the deletion of your personal data without undue delay. However, Company may deny your deletion request if retention of your personal is necessary for the purposes for which the data were collected.

• Restriction of processing

You have the right to request that the processing of your personal data is restricted. There is a risk that we will be unable to provide you with our services during the time the processing is restricted.

• The portability of personal data

Under some circumstances you have the right to gain access to your personal data in a structured, commonly used and machine-readable format (data portability) and have the right to transmit those data to another controller (if it’s technically possible). This right is limited to personal data that you have provided us with, if it is being processed for the purpose of fulfilling a contract with you or based on your consent.

• Non-discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by the CCPA, we will not a) deny you use of our Services, b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, c) provide you a different level or quality of services, d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

• Other information

You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

K. How can you get more information and enforce your rights?

In case you have questions about the processing of your personal data or you want to know more information, you can contact us by writing to us at: PIXEL FEDERATION, s. r. o., with registered residence: Einsteinova 19, Bratislava 851 01, Slovakia, or by e-mail address: [email protected] or [email protected].

This document will be regularly updated. Status as of 1st of November 2020.