PRIVACY AND DATA POLICY
ISSUED BY WARCHEST LIMITED
Last Updated: March 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by WarChest Limited. (“WarChest” / “we" / “us”). Our office is at Royal Court, 81 Tweedy Road, Bromley, BR1 1RG. We are a company registered in England, with company number 07783664.
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal information you have provided to us.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information, which may include your personal data.
Information provided by you when using the Game (“Basic Information”)
We will collect the following information from you when you play our Games:
This may include:
- Steam ID;
- Steam Profile/Display Name; and
- chat history; and
- your IP address; and
- your location
Contact information provided by you when using the Forums (“Contact Information”)
We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Forums.
This may include:
- your email address;
- your username; and
- your password.
How you use our Online Services (“Analytics”)
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
- your Steam ID;
- your Steam profile / display name;
- your IP address;
- game play results (e.g. wins/losses, kills/deaths);
- game play progress;
- game time;
- user interface usage (e.g. buttons clicked, screens viewed);
- hardware information (e.g. CPU, RAM, video card configuration);
- any purchases and spend you have made in the Game; and
- identification of crashes and bugs.
We use the following third party analytics providers when conducting our analysis:
- Google Analytics - google.com/policies/privacy
- Delta DNA - http://go.deltadna.com/rs/554-FYX-755/images/GDPR.pdf https://deltadna.com/privacy
- PowerBI - https://powerbi.microsoft.com/en-us/terms-of-service
- Bugsplat - https://www.bugsplat.com/privacy
- Easy Anti-Cheat - https://www.easy.ac/r/privacy/statement/21/
These third party analytics providers may collect analytics on our behalf and in accordance with our instructions and their applicable privacy notice.
You can find out more about the way they collect and process this information by following the above links to the privacy notice and/or terms and conditions for each applicable third party analytics provider.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Game and the Online Service to you
This processing of information in this way is necessary for us to make the Online Services available to you, and ensuring that they function properly so that you have the best experience when playing the Game and/or using the other Online Services.
To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve the Game and Online Services. We will only do this in the following ways and only if you have provided your consent in this respect:
Analytics: We would like to collect and use information about how you play the Game, and analyse it to understand playing behaviour and to compile statistical reports regarding that activity. You can withdraw your consent to this at any time by going into your account settings and ticking a different box.
Requests for voluntary feedback: From time to time, we will offer you the opportunity to provide feedback on the Game via a free form text box. It is entirely voluntary and you are free to decide what information you provide to us.
Voluntary crash reports: If the Game encounters a problem and needs to close, we will give you the opportunity to submit a crash report. It is entirely voluntary and you are free to decide what information you provide to us.
This processing will enable us: (i) to ensure that our Online Services function properly so that you and other users have the best experience when playing the Game and using the other Online Services; and (ii) to identify and correct any bugs in the Game and Online Services.
To respond to your enquiries and requests for support and to enable you to use the Forums
Prevent Fraud and Illegal Activity
We process personal data for the legitimate interests of ensuring that use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
We work with Steam (the Valve Corporation) to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-Game purchases made through Steam). We also work with Easy-Anti-Cheat (operated by Kamu Ltd.) to detect cheating. Please see the section on "automated decision making" for more information on this.
4. DATA SHARING
We will store personal information via our cloud-based data storage provider: Amazon Web Services, Inc. https://aws.amazon.com/compliance/data-privacy-faq/
Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of WarChest, our customers or others.
Digital Content Stores: The Game is made available to download via Steam (operated by the Valve Corporation) and we may disclose your personal information to Steam for the purposes of making the Game available and facilitating any in-Game payments made through Steam.
5. AUTOMATED DECISION MAKING
We work with Easy-Anti-Cheat (operated by Kamu Ltd.) to detect cheating.
We process your personal information via automated decision-making methods in order to identify users who are cheating in the Game. Our automated decision-making methods are designed to detect cheating by looking for irregularities in game play behaviour.
If users are determined to be or suspected of cheating, the following actions may be taken:
- - they will be indefinitely suspended from playing the Game, although they will still have access to their Game account; and
- - anything acquired relating to the Game, be it through credits or real-money purchase, will be lost.
In this scenario, the user will be informed of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Game. If this applies to you, please contact us at firstname.lastname@example.org.
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
Where you have linked your Steam account to any of your social media accounts, you can unlink these at any time by changing your settings in Steam. You can also remove access in your account settings on Facebook, Twitter and/or YouTube.
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay and within one month at the latest.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
You can download a copy of your Game account information by following the instructions in your account settings.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing or delete your personal data if:
- you consented to our processing the personal data and have withdrawn that consent;
- we no longer need to process that personal data for the reason it was collected;
- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of WarChest or a third party, you don’t agree with that processing and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed;
- you need the personal data to be deleted in order to comply with legal obligations;
- the personal data is processed in relation to the offer of a service to a child.
You can delete your Game account by following the instructions in your account settings.
Obtain a machine-readable copy of your personal data, which you can use with another service provider
- If (i) we are processing data in order to perform our obligations to you or because you consented and (ii) that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
- If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
- If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
8. DATA RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements
If you decide to delete your Game account, we will delete your account information within 28 days.
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password-protected and encrypted using Transport Layer Security (TLS) and Secure Sockets Layer (SSL).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
11. INTERNATIONAL DATA TRANSFERS
Information we collected about you will be stored within the European Union (EU) on a secured server.
Your personal information may be transferred outside of the EU by Steam (i.e. Valve Corporation), Google, Delta DNA, Power BI, Bugsplat or Easy Anti-Cheat.
Where we transfer your information outside of the EU, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to us at email@example.com.
All questions, comments or enquiries should be directed to WarChest at firstname.lastname@example.org. We will endeavour to respond to any query or questions within two business days.
© 2018 WarChest Limited. All trade marks are the property of the relevant owners. All rights reserved.