Effective 19 November 2018

We are committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) describes how we treat information that you provide to us or that we collect about you.

By “Personal Data”, we refer to data that relates to you as an identified or identifiable natural person. The term “Personal Data” may include your name, your address, your telephone number, your e-mail address, your age, your gender, your game preferences, for instance. Anonymous information, which we are not in a position to relate to you, does not qualify as “Personal Data”.

1. CONTROLLER’S NAME AND CONTACT DETAILS
Controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding our websites owned or operated by Redhill Games: 

Redhill Games Oy
Töölönlahdenkatu 2
00100 Helsinki
FINLAND
Email:  info@redhillgames.com

2. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)
The contact details of Data Protection Officer of Redhill Games are:

Redhill Games Data Protection Officer
Zinonos Sozou, 12
Nicosia 1075
Cyprus
Email:  info@redhillgames.com

3. GENERAL INFORMATION IN BRIEF
We process personal data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms for which require the protection of your Personal Data.

Our legitimate interests are to render and improve our Services in an effective, safe and harmless manner. We want to provide everyone with a fair and balanced experience when using our Services.

3.1. YOUR PREFERENCES
You can choose how we use your Personal Data by sending us a request at info@redhillgames.com.

3.2. INFORMATION SECURITY
We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. 

3.3. PROCESSING INFORMATION BY THIRD PARTIES
We may share Personal Data with our affiliates, subsidiaries, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services. Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.

3.4. DATA RETENTION
We keep most of your Personal Data gathered and processed for the purposes described in this Policy for as long as you continue to use our Services, e.g. you visit our websites or send us communication.

4. INFORMATION WE COLLECT
In relation to your use of our Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g. through our Site’s technology).

4.1. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information.

Content Data

We may obtain your Personal Data when you register for and use our other Services, e.g. game forums, chats, or when you provide feedback about our Services. This data includes: 

• Information that you post, comment or like in any of the Redhill Games-related forums owned or operated by Redhill Games (“Forums”), on the pages of social network groups operated by Redhill Games, and on the sites;
• Information that you provide to us to become a participant of UX tests, alpha-tests, super tests.
• Information that you provide to us offering your partnership or services.

4.2. INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our Sites and social media pages. This information may include, but is not limited to, anonymized browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information (“Other Information”). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If Other Information is combined with Personal Data, we will treat the combined information as Personal Data.

4.2.1. Tracking Data and Cookies
We and our partners, such as marketing partners and analytics providers, use “Cookies”, which are text files placed on your computer, to help us analyze how users use our Services, and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different devices and our Services, as well as to improve the Services we are offering, to improve marketing, analytics or website functionality. The use of Cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our Sites.

Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as “Tracking Data”. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. When you visit our site, our servers log your computer’s IP address.

4.2.1.2. How to delete cookies and opt out of targeted advertising and analytics
Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

If you wish to limit behaviorally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out will take effect.

For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).

For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies (e.g. https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en for Chrome), and by visiting the following sites: 

• http://www.aboutads.info/choices
• http://www.youronlinechoices.eu

We also work with a number of other analytics and ad serving partners within our mobile apps and websites. These partners can use cookies, web beacons, and other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For more information about their privacy practices and opt-out possibilities, please visit the links below.

• Google Privacy Policy: https://policies.google.com/privacy
• Facebook Privacy Policy: https://www.facebook.com/about/privacy
• LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy

4.2.2. Information from publicly available online resources
We may use the information made publicly available, e.g. through YouTube, vk.com, Facebook, Instagram and Twitter, in order to find out your opinion about the Company and Services, so that we could take them into account while improving our Services. Such data collection can be carried by Redhill Games independently, or received from our partners making analysis of public sentiments on various issues.

4.2.3. Information from our partners
In some cases, Redhill Games receives your personal data as a data processor, which means that the data is controlled by our partners and we use it only in accordance with their instructions and applicable laws. We use this data in order to fulfil our obligation under the EULA, improve the Services, and when processing is required in order to comply with a legal obligation to which we are subject.

Social networks. We have registered certain Redhill Games-related accounts and pages at Facebook, Twitter, Instagram, LinkedIn, and other social networks to better communicate with our partners, candidates and [players] in case they have questions about the services, as well as prefer to learn about news about the services through the social networks. Also, we get information relating to your profiles on social networking sites in order to allow integration with such social networking sites, e.g., your name, avatar, and date of birth, if you link a third party tool with our services.

5. HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to perform the contract with you according to Article 6(1)(b) of the GDPR. As a user, we will use your Personal Data, unless otherwise prohibited by law, for the following purposes:

• to provide you with the Services you request;
• to retain services you offer;
• to take you through the recruitment process.

5.1. SERVICES IMPROVEMENT PURPOSES
We analyze your information to identify how to improve the Services and our operations to make them more suitable and interesting for our players in general. We also may ask you to respond to our Services-related questionnaires, and you always have the choice about whether to respond to them and which information you provide.

6. HOW WE SHARE YOUR INFORMATION
For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data with the following categories of third parties:

1. Publicly available information: our Sites may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk.
2. Public authorities and auditors: some personal data shall be disclosed to public authorities, e.g., tax and customs authorities, auditors, and other competent parties, in accordance with Union or Member State law;
3. Change of control: we may share your data as part of our company’s sale, merger or change in control, or in preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy unless you are specifically informed otherwise.

When your personal data is shared with Redhill Games affiliates and subsidiaries, as well as third parties outside the European Union or the European Economic Area, Redhill Games guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with Redhill Games affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the standard data protection clauses upon your request.

7. YOUR RIGHTS
Send us your request at info@redhillgames.com in order to exercise your data protection rights (data erasure and objection to data processing).

7.1. RIGHT OF ACCESS
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. Normally, we provide the duplicate of the Personal Data retained within 30 (thirty) days upon your request. Once the archive with the Personal Data we retain is ready, you will be able to download in it from our resources. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. We also will not be able to provide you with some Personal Data that you may post or provide using our Services regardless of our request not to provide the Personal Data in this particular field, website, etc. 

8. WE CAN CHANGE THIS POLICY
We may change this Policy from time to time for various reasons, such as legal and regulatory changes, changes in industry practices and technological developments that need to be reflected. The updated version of the Policy will be published on our website.