Last updated: 02 October, 2018
We will review this Policy from time to time to make sure it is up-to-date. If we make changes, we will post the latest version here. When we make significant changes, we will let you know when you next access our Services or by other communications.
This Policy should be read along with our User Agreement at https://survarium.com/en/user-agreement ("User Agreement").
In the case of any contradictions between this Policy and our User Agreement, this Policy will prevail.
In this Policy Personal Data is any information that can identify you as an individual ("Personally Identifying Information") or that can be connected to you indirectly by linking it to Personally Identifying Information.
We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. We may share anonymous data, aggregated or not, with third parties. These cases are listed in the chapter 3 hereof.
We do not check information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
2. Why do we use your Personal Data
We only use your Personal Data for the following reasons:
where you've given us your consent;
where it's necessary to deliver the Services you've requested;
where it's necessary to exercise or comply with legal rights or obligations that we are subject to; or
where it is necessary for the purposes of the legitimate and legal interests of us or a third party, except where such interests are overridden by your prevailing legitimate interests and rights.
Your Personal Data may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims.
In order to implement the agreement between you and us, and provide you with access to the use of our Services, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organize, extract, compare, use, and supplement your data (these actions will/may further together be referred to as "processing"). We will also receive and pass this data as well as our automatically processed analyses of this data to our affiliates and partners (as set out below).
3. What Personal Data and how do we collect and process it
3.1. Account Data
When registering and setting up an Account (as defined in the User Agreement), we will collect your e-mail. You may register in our Services via your social accounts or accounts of our third party network partners such as digital distributors and publishers. But in this case registration of Account is also required. You are required to choose password to your Account and you may choose a user name. During setup of your Account the Account is automatically assigned a number (the "ID Account") that is later used to reference your Account without directly exposing Personally Identifying Information about you. Likewise, we use API of your digital distributors' and publishers' account to reference your Account without directly exposing Personally Identifying Information about you.
We make certain data related to your Steam User Account available to other players and our partners through the Steamworks (https://partner.steamgames.com).
We use this information in order to provide our Services to you, to manage and administer our Services and as additional information to verify your Account to prevent abuse and infringements of your or other persons' rights.
We also use this information in order to provide you with updates and information on our and third parties' products and services that we think you may be interested in.
We also use this information in order to tailor and improve the advertisements that are presented on our Site and measure the effectiveness of these advertisements.
We do not require you to provide or use your real name for the setup of Account, moreover we insist on not using your real name for the setup of Account.
3.2. Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others. This data may include:
information that you post, comment or follow in our Services;
information sent through message boards, forums, chats;
information you provide in feedback or other user generated content when you request information or support from us or purchase our Services;
information you provide to us when participating in competitions, contests and tournaments or responding to surveys.
When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available online to internet users and can be copied and/or disseminated by any users. Once this data is transferred by you to other users you will not be able to delete this data. Therefore, you are doing so at your own risk.
Once you have provided this data it will be accessible by other Site users and it becomes difficult for us to remove this data but we will always undertake all necessary measures to do so.
We use this information in order to verify your identity and to fulfill your support request.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.
We may also share your data with our third party contractors and software developers provided these third parties assume confidentiality obligations regarding your personal data collected by your use of the applications they offer. The developers use the information provided to them in order to provide you with Services. Usage of such information by the developers with the purpose mentioned herein is always carried out according to the highest standards of personal data protection.
Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data.
3.3. Your Use of our Services and our Site
In order to provide you with Services, we need to collect, store and use various information about your activity and the result of your behavioral actions in our Services which is usually referred to as "game statistics". By game statistics we mean information about your in-game actions, achievements, badges, preferences, progress in the games, playtime, your multiplayer game matchmaking information, in-game items, crash data, and other information needed to operate the game and provide support for it. Information mentioned above is anonymized and doesn't allow identifying your personality.
This information in the anonymized form can be available to other users of our Services and to other third parties on other websites.
We may also use this anonymized information in order to tailor and improve the advertisements that are presented to you to and measure the effectiveness of these advertisements.
What is a cookie?
Cookies record things like your preferences and settings (e.g. your IP-address, time of access to our Services, country and language settings, your browsing behavior).
We use this information for internal review in order to provide you with the most consistent and relevant experience, including to constantly improve the content of our Services and our Site, to understand any errors you may encounter when using our Services, to notify you of changes to the Services and to personalise the use of our Services, and to record information about experiments or new improvements we might test to track how you use our Services and find out whether they were effective. We also use this information in order to tailor and improve the advertisements that are presented on our Site and measure the effectiveness of these advertisements.
Cookies on our Site may be set by us, third parties we're working with, or independent third parties (such as advertisers).
3.5. Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on visitors' computers, to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on servers in the United States.
On our Site, IP anonymization has been activated. The IP addresses of users visiting our Site will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and shortened there. On behalf of operator, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout?hl=en
3.6. Content Recommendations
We may process information collected under this Policy so that content of our Services shown on the webpages of our Site and update messages displayed when launching our Services can be tailored to meet your needs and populated with relevant recommendations and offers. This is done to improve your customer experience. You can prevent the processing of your data in this way by turning off the automatic loading of such web pages and our notifications in your Account settings.
We may send you marketing messages about our Services offered by us to your e-mail. In such case we may also use your collected information to customise such marketing messages as well as collect information on whether you opened such messages and which links in their text you followed.
You can opt out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the "unsubscribe" link provided in every marketing email.
Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age or location, or to target communities according to type. If you fall within one of the target groups, you will receive an advertisement or recommendation.
3.7. Mailing address
We may collect and process information about your mailing address when we deliver any goods that are ordered by you e.g. T-shirts. We will delete this data after receipt of such goods by you and after end of the warranty period.
4. How Long We Store Personal Data
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
If you terminate your User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.
In certain cases Personal Data cannot be completely deleted in order to ensure the consistency of the gameplay experience (e. g. matches you have played that affect other players' matchmaking data and scores). Rather, your connection to this Personal Data will be permanently anonymized.
If you withdraw your consent on which a processing of your Personal Data is based, we will delete your Personal Data respectively without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.
If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
5. Who Has Access to Personal Data
We and our affiliated companies may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in this Policy. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.
We may also share your Personal Data with our third party providers that provide customer support services in connection with Services distributed via us. Your Personal Data will be used in accordance with this Policy and only as far as this is necessary for performing customer support services.
In accordance with internet standards, we may also share certain information (including the identification of content you wish to access) with our third party network partners such as digital distributors and publishers.
We may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.
6. Your Rights and Control Mechanisms
You can access, edit, download, or delete your Personal Data associated with your User Account at any time by going to your User Account. From here you can also manage your subscription and marketing preferences.
You also have rights in relation to the personal data we have about you, which we explain in more detail below. You can exercise these rights by getting in touch with us via our support services.
a) Right of Access
You have the right to access to your Personal Data, to ask us for a copy of your Personal Data, or to obtain your Personal Data in a structured, machine readable format. We will need to verify your identity before we are able to disclose any personal data to you.
b) Right to Rectification
You may independently make changes and corrections to your Personal Data on your Account or you can request that we update your Personal Data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
c) Right to Erasure
You may request that we block or delete your Personal Data. Alternatively, you may require deletion of your Account via support service.
As a result of deleting your Account, you will lose access to our Services.
We allow you to restore your Account during a grace period of 30 (thirty) days from the moment you request deletion of your Account. This functionality allows you not to lose your Account by mistake, because of your loss of your account credentials or due to hacking. After the grace period, Personal Data associated with your account will be deleted.
In some cases, deletion of your Account, and therefore Personal Data deletion, is complicated. In these cases, considering the complexity and number of the requests, the period for Personal Data erasure may be extended, but for no longer than two further months, or your Personal Data will be anonymized.
d) Right to Restrict the use
e) Right to Object
When our processing of your Personal Data is based on legitimate interests, you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, in particular if the data is necessary for the establishment, exercise or defense of legal claims.
You can object to the processing of your Personal Data in some circumstances (in particular, where we don't have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to processing your data by us, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required to keep by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.
To the extent that you're unable to satisfactorily exercise any of these rights via your Account, you can do so by contacting our support service.
f) Right to Portability
g) Right not to be subject to an automated decision
h) Right to lodge a complaint with a supervisory authority.
If you have unresolved concerns, you have the right to complain to a data protection authority.
The minimum age to create an Account is 13 (thirteen) years. We will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, we require parental consent before an Account can be created and Personal Data associated with it is collected. We encourage parents to instruct their children to never give out personal information when online.
8. Privacy Settings
The Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.
We bear no liability for the actions of third parties which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.
We bear no liability for the consequences of use of the information which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site.
9. International Transfers
We may transfer and maintain on our servers or databases some of your Personal Data outside the European Economic Area (EEA) including in France.
The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in agreements with our partners the standard contractual clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
10. Security Measures
We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your Personal Data is protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
Access to the Services is authorized using your login and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
If you forget your login details, you can request us to send you an email, which will contain a restoration code.
To reduce the probability of third parties' gaining unauthorized access to the Account, if you login to your Account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your Account. You will then need to contact Service support and provide certain additional information to verify your credentials and gain access to your Account.
11. Who are we and how can you contact us?
Our Services are provided by EDIS INVESTMENTS COMPANY LTD
We are the Data Controller of any information collected from you by us.
To contact our support service, please send your email to: firstname.lastname@example.org