IMPORTANT! PLEASE READ CAREFULLY BEFORE YOUR REGISTRATION OF BEING ONE Camel Games USER!
THE CAMEL GAMES INTERACTIVE PRIVACY POLICY
SUMMARY
With this privacy policy (the 'Policy'), we want to let you know how we at Camel Games Limited, established in the United States, with the address 9/F., MW Tower, No.111 Bonham Strand, Sheung Wan, Hong Kong (herein 'Camel', 'we' or 'us'), promise to take care of the personal information we collect from you. This includes the information you provide us with (for example, when opening a game account or subscribing to our official media platforms), what we learn when having you on our platforms and when you are playing our games. All our games are called Camel Games.This Policy explains which personal information we collect from you and for what reasons; how we use, store transfer such data; and also how you can contact us to ask about your data and invoke your rights.
We only collect, use, store and transfer ('process') your personal information in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation (2016/679) ("GDPR") and applicable national data protection legislation (hereafter 'applicable law').
Depending on whether you are a website visitor, customer and/or a user of our Services, we will process personal information such as your contact details (email address, telephone number and postal address), your username, password(s) and payment details. We will also collect and use information about your technical equipment such as your hardware and software type and location data, and other information you provide us with, for example when you sign up for our surveys and contests. For more information about the personal information we collect, use and otherwise process, please see section 6 below.
We will use your personal information for different purposes. We will for example use the data to provide you with the Service you have requested, to improve our games and other Services, to predict user trends, to make recommendations based on your usage, and to process payments. For more information about how we use your data, please read on below.
We will engage other companies in order to fulfill our purposes and obligations as set out in this policy, and we will transfer your personal information to countries outside the EU and EEA that may not have as strict privacy legislation as where you live. We will only transfer your personal information to such countries if we are allowed to do so; please read below for more information. When we collect personal information about you, you are entitled to the following rights under applicable law:
The right to access and rectify your personal information;
The right to object to our processing of personal information;
The right to restrict to our processing of personal information;
The right to demand us to delete your personal information; and
The right to data portability.
For more information about the rights you have in relation to your personal information, please contact our support team. If you have any questions about the personal information we collect, how we use your data and how we transfer your data to fulfill our purposes as stated herein, please contact us at: [email protected]. Below follows a more detailed description of how we use personal information.
CONTENT
WHO WE ARE
What we promise
What is personal information?
Reasons for processing of your data
When do we collect your data?
What data do we collect?
How do we use your data?
Who do we share your information with?
Can children use our services?
Security measures to protect your data
If you choose not to share your data with us
How long will we keep your data?
Accessing, changing and updating your data
Right to object to the processing of your data
Right to erasure
Right to restriction
How to get a copy of your data or receive a copy of your data
How to enforce your rights
How to withdraw your consent or close down your Account
Changes in the privacy policy
How to contact us and how to complain
DPO CONTACTER INFORMATION
1. WHO WE ARE
We are Camel Games Limited ('Camel', 'we' or 'us'). This Policy applies to websites operated by us and any other of our affiliates. This Policy also applies to your use of our services, such as our official forums or Facebook page, and also when you use and play our games or other products (we call all of the above 'Services').
We are the controller of the personal information collected. If you have any questions or want to know more about how we use your personal information, please contact us by logging in to your Camel Games account and directly contacting our Support Department through the in-game Feedback system, or email us at [email protected].
2. WHAT WE PROMISE
We promise to keep your data safe and to not to sell your data to third parties. We promise to give you the right to access and delete your data, and to provide you with ways to manage and review your marketing choices as well as any other information (such as for example newsletters) you get from us.
3. WHAT IS PERSONAL INFORMATION?
Personal information can be any information relating to an identified or identifiable natural person. In other words, it can be any information that could allow us to identify you both directly and indirectly (like for example your name, email address, IP address, or your billing address). In this Policy, we will use the word 'data' to refer to personal information.
4. REASONS FOR PROCESSING OF YOUR DATA
We will only use and process data about you if we have one of the following reason to do so:
To fulfill a contract we have with you (for example, when you have made an in-app purchase in Camel Games);
When it is our legal duty (for example, to identify your age and make sure we are not collecting data from young children, for book keeping purposes, and to fulfill our obligations in relation to authorities);
When you consent to it (for example, when binding a specific game account to a third-party account); or
When it is in our legitimate interest (for example, to enforce our policies, manage our everyday business, to use in an anonymized and aggregated way in order to perform statistical analysis, for direct marketing purposes, to ensure information security, to prevent fraud or to transfer the data to different part of the organization when necessary). When we rely on a legitimate interest we have concluded that our interest is not overridden by your interests or fundamental rights and freedoms. You are welcome to contact us to learn more about how we have reached this conclusion.
5. WHEN DO WE COLLECT YOUR DATA?
We will collect data about you when you use our Services, including in the following situations:
When you register a Camel Games account
When you use a relevant function
When you purchase an in-game product
When you play our games
When you register on and use our forums
When you contact us or our support services, via emails or letters
When you use our websites, apps, or games
In customer surveys
If you participate in user research initiatives
If you participate in a playtest or prelease test such as alpha/beta/etc. test releases/beta
If you take part in our competitions or promotions
When you enroll in, or participate in, one of our events
When you send us a game pitch
When you click on one of our ads or in our newsletters
When you subscribe to receive our press releases
you log in to our Services using third party account
When you work for Camel. In such case, please contact our Human Resources department separately for more information.
6. WHAT DATA DO WE COLLECT?
We use data that you have explicitly provided to us in different situations. We also use personal information that is generated by your device or when you use our Services. These categories are further explained below. Data that you explicitly provide us with:
Username
Country of residence
Name
Password(s) created to access parts of the Services
Nicknames on forums and in games
Device information
The above information may be provided to us when you open a Camel Games account, or when you subscribe to our social media events and platforms. In addition to the above, and when purchasing a game product or enrolling in an event, you may have to provide us with the following data:
Physical address
Telephone number
Billing receipt information
Third-party account info such as email address, Facebook name, etc.
Finally, any other data you actively provide us with when:
You contact support or seek help from Camel Games
You fill in our surveys or join our playtests
You enter a contest. If you win, we might need additional information about you depending on the specific contest. We will, however, only collect such information with your consent
You apply for a job at Camel Games and provide information relevant to the application. For more information on how we use personal information in that respect, please refer to the privacy policy available on our job applications website.
Data we collect when you use our Services or games:
Profile and usage data. This includes the profile you create to identify yourself when you connect to our Services and internet protocol (IP) address that may uniquely identify you when you connect to our games. It also includes other data about how you use our Services and games. We gather this data from devices you use to connect to those Services, such as smart phones and tablets.
Payment and transaction data
Location data
Platform type (Android, iOS)
Preferred language
Gender
Information about your device, hardware and software
Your device’s IDFA (if you’re an iOS user) or Google ad ID (if you’re an Android user), or other platform information such as your IP address or Google Play ad ID.
In-game activity including but not limited to what games you play, own, how you play, how often and for how long
Game crash report(s) and error dump information from your device
Activity carried out within our Camel Games application, including install, uninstall, and update event information
We will always ask for your consent to give us details on your location data.
Data from third parties we work with: We may receive data about you from third parties or partners, like for example Facebook, Google, and Appsflyer.
We may also receive information from third parties (such as game distributors) to add to the information we receive from you. This is used to help us deliver relevant advertising to you, to prevent fraud and/or abuse, and to collect your geolocation for taxation purposes.
7. HOW DO WE USE YOUR DATA?
We use the information we collect from you and from your use of our Services, to provide, maintain, protect and improve the Services and to develop new ones. Unless you have told us not to (opt out), we also use the information to offer you tailored content, like giving you more relevant ads and inform you about game releases that you might be interested in. We will not use your data for any other purpose than the purpose for which the data is originally collected.To operate our business and to enhance your gaming experience, we use your information in the following ways:
To operate, improve, develop and provide you with our games, apps and Services
To provide you with recommendations and game offers that you may like
To respond to inquiries or comments from you
To verify your identity in order to prevent unauthorized access
To provide you with software updates
To understand trends in usage
To calculate marketing conversion rates and other elements of advertising performance
To help tracking and correcting errors and bugs in games and services
To customize your user experience
To maintain the integrity and security of the Services
To process transactions and communicate with you regarding these transactions
To maintain or administer your Camel Games account, including contacting you in order to update your Camel Games details if necessary
To administer and perform play- and beta tests which you have signed up for
To create reports, analyses or similar for the purpose of research and business intelligence and be able to track potential problems, behavior and trends
To enforce our terms and conditions, such as our EULA, Terms of Use, Rules of Conduct and this Policy
To send you newsletters and promotional notices and offers you have previously agreed to
To keep our Services fair, investigate and prevent fraud and illegal behavior
To comply with applicable laws and regulations
Special information about marketing:
Special information about marketing: We use your data to inform you about relevant products and offers, e.g. provide you with targeted marketing. The data we collect in such cases contain information that you willfully provide us with, the data we collect when you use our Services or from third parties we work with. We analyze this data to form a view on what we think you might want or need or what may be of interest to you. You can at any time object to our use of your personal information for marketing purposes, including any profiling for such purposes, and we will then stop using your personal information for such purposes.
8. WHO DO WE SHARE YOUR INFORMATION WITH?
To be able to provide you with the Services and the best possible experience, we will share your data with other companies and organizations. We will only do so if our partners can provide the same level of security to keep your data safe as implemented by us and if our partners can ensure that they comply with applicable laws and privacy regulations. We may share your information with the following partners:
Game distribution platforms (for example, Google, Apple, and Amazon)
Advertising partners and attribution platforms to help us understand the effectiveness of our marketing campaigns (for example, Google, Facebook, and Appsflyer)
Please note that our games or products may be advertised in other applications. If you click on one of these advertisements and install our game, you will become a user of our Services. To prevent fraud and verify the installation of the game, we may share your IDFA (iOS) and/or Advertiser ID (Android) with the relevant advertiser.
For Services using the Unity Engine, Unity is our service provider. Unity may collect certain data in relation to your use of such Services. You can find their privacy policy on their websites under https://unity3d.com/legal/privacy-policy.
We may release your data when we are required to by a court order, according to law or in the event of a bankruptcy or other similar unfortunate event.
We may also share and may acquire your data with future subsidiaries or companies if we choose to sell, transfer or merge parts of our business. We will, however, only transfer the data if we must and if these companies comply with applicable privacy regulations and can guarantee that your data will be kept safe.
9. CAN CHILDREN USE OUR SERVICES?
Our Services and games are not directed to children and we do not knowingly collect information from children under 13 years of age. From May 25, 2018, only children over 13 years old are allowed to open a War an Order account. We strongly recommend parents or guardians to instruct their children to not disclose any data when online. Parents or guardians who are concerned about the transfer of data are welcome to contact us at [email protected]. If we obtain actual knowledge that we have collected data from a child, we will promptly delete it, unless we are legally obligated to retain such data.
10. SECURITY MEASURES TO PROTECT YOUR DATA
We maintain physical, electronic and procedural safeguards to help guard your data in compliance with applicable privacy regulations. If transactions are offered on the Services, transaction information is transmitted to and from the Service in encrypted form using industry-standard Transport Layer Security (TLS used to be known as SSL) connections to help protect such information from interception. We strictly restrict authorized access to your data only to those persons who have a legitimate purpose to access it. We also have security measures in place to protect the loss, misuse and alteration of the data we process.We maintain physical, electronic and procedural safeguards to help guard your data in compliance with applicable privacy regulations. If transactions are offered on the Services, transaction information is transmitted to and from the Service in encrypted form using industry-standard Transport Layer Security (TLS used to be known as SSL) connections to help protect such information from interception. We strictly restrict authorized access to your data only to those persons who have a legitimate purpose to access it. We also have security measures in place to protect the loss, misuse and alteration of the data we process.
11. IF YOU CHOOSE NOT TO SHARE YOUR DATA WITH US
We may need to collect data to be able to fulfill our legal obligations or fulfill the terms of a contract we have with you or to be able to even present you with the Services. If you choose not to give us this data, it may prevent us from meeting our obligations. It may also mean that we cannot perform the Services needed to run your Camel Games account or policies. It may also mean that we have to cancel a product or Service you have with us.
12. HOW LONG WILL WE KEEP YOUR DATA?
We will keep your information for as long as you are a player or customer of Camel. We may keep your information for longer for research or statistical purposes. If we do, we will make sure your information is anonymized and non-traceable to you as a person. We will also keep it for longer if we cannot delete it for legal or regulatory reasons. We will however delete all data that is no longer necessary after a reasonable period.
13. ACCESSING, CHANGING AND UPDATING YOUR DATA
When you use our Services, we strive to provide you with ways to quickly update or delete data that you have actively provided. You have the right to access the data relating to you. This includes the right to be informed whether or not data about you is being processed, what data about you is being processed, and the purpose of the processing. You also have a right, upon your request, to access information about any evaluation or assessment of the balancing test we are required to conduct when we process your data based on our legitimate interest. Furthermore, you have the right to rectify or add data if the personal information is inaccurate or incomplete. As soon as we become aware of any inaccurate personal information being processed, we will always rectify your data without undue delay and notify you accordingly. If you have created a Camel Games account, you can use the in-game Contact Official function or email [email protected] to contact us regarding your data.
14. RIGHT TO OBJECT TO THE PROCESSING OF YOUR DATA
You are also entitled to object to the processing of your data on grounds related to your particular situation. Please note however, that we must still process some personal information about you to provide the Services to you. This means that you cannot object to all our use of personal information and still require us to provide Services to you.
15. RIGHT TO ERASURE
You are entitled to request that we erase data related to you. We will erase your data upon request provided that it is no longer necessary for the purpose (for example you cannot require all personal information about you to be erased and still receive Services from us) or we have a legal obligation to store personal information.
16. RIGHT TO RESTRICTION
You are entitled to require us to restrict our processing of your personal information if you contest the accuracy of the data, if the processing is unlawful but you do still not want us to erase the data, if the data is no longer needed to fulfill the purpose it was collected for or you have informed us that you do not consider us to have a legitimate interest for certain processing.
17. HOW TO GET A COPY OF YOUR DATA OR RECEIVE A COPY OF YOUR DATA
You can request a copy of your data by logging into your Camel Games Account and contacting our official support team through the in-game “Contact Official” function, or by emailing [email protected]. If you request access to personal information about you that you yourself have provided, and if the personal information is being processed automatically and in accordance with a contract between you and Camel or based on your consent, you may request that the data is provided in a structured, commonly used and machine-readable format and you may also request that the personal information is transmitted to another controller, if this is technically feasible.
18. HOW TO ENFORCE YOUR RIGHTS
You can contact our Support department by logging into your Camel Games account and using the Contact Official function or emailing [email protected] at any time to get a list of all the data we have collected from you or to get such data deleted or invoke your other rights as explained above. We will do our bests to answer your request in a timely manner but please note that it may take a couple of days. Thank you for your patience and understanding.
Please note that if we cannot identify and guarantee who you are, we might ask you to provide us with additional information or log into your Camel Games account if possible. Please note that we will not delete any data if we are unable to verify that you are their rightful owner. We will however always use our best effort to help you out.
19. HOW TO WITHDRAW YOUR CONSENT OR CLOSE DOWN YOUR ACCOUNT
You can contact our official Support team to close your account. However, if your account is closed, we may be unable to provide you with certain Services, and your game experience may be affected. Closing your game account will result in the loss of all of your game progress, virtual currency, virtual items, and ability to access the game.
20. CHANGES IN THE PRIVACY POLICY
This Policy may change from time to time. Any changes to this Policy can be checked at any time in the in-game Privacy Policy, and if the changes are significant, we will provide you with a more noticeable notice, like for example by game mail or with a pop-up in our games or on your Camel Games account page. If you are asked to accept material changes to this Policy and decline to do so, you might not be able to continue using the Services with all functionality preserved.
21. HOW TO CONTACT US AND HOW TO COMPLAIN
Please let us know if you are not happy with the way we use and process your data by contacting our Support department at: [email protected].
We will also appreciate to get feedback from you if you think that this Policy or any part of it is unclear. Our address is: 9/F., MW Tower, No.111 Bonham Strand, Sheung Wan, Hong Kong.
22. DPO CONTACTER INFORMATION
DPO contacter: Monica Lee
E-mail: [email protected]