Confidentiality Policy of the Limited Liability Company “ENHANCED PLAYER EXPERIENCE”
Version No. 1 dated the 1st of November 2018
The Limited Liability Company “ENHANCED PLAYER EXPERIENCE” (hereafter – Company) undertake liabilities for protection and observation of the rights of users of the website and the Game (as will be defined below) regarding personal data (as will be defined below – Data concerning you). The present Confidentiality Policy (hereafter – “Policy”) sets the procedure of data processing made by the Company, the data being provided to us by you or which we collect ourselves.
When speaking about “Data concerning you “ and “Your data” we refer to Personal data within the meaning of applicable legislation of an identified or identifiable legal entity. “Data concerning you” comprises your name and surname, address, phone number, e-mail address, age, sex, game settings. Anonymous information that we cannot relate to your identity is not referred to the category “Data concerning you”.
1. NAME, SURNAME AND CONTACT DETAILS OF THE PROCESSOR/ CONTROLLER
The Personal Data Processor, i.e. a person collecting and processing your data as set by the legislation of the Russian Federation, and the Controller in accordance with the General Data Protection Regulation (GDPR), and by other laws on data protection or confidentiality in the European Union Member States, as well as by other requirements to data protection in relation to our online-game “Population Zero”, and our website correspondingly: https://pzonline.com, and any other games and websites of the Company on which such Policy is available, is:
Limited Liability Company “Enhanced Player Experience”
OGRN (Primary State Registration Number) 1167746892169
IIN (Taxpayer Registration Number) 7719457568, KPP (Registration Reason Code) 771901001
Registered office: 107023, Russia, Moscow, 14 Mazhorov lane, building 8, floor 3, suite 8301
The definition “Resources” means the opportunities provided for you to be able to play the above-mentioned game (hereafter – “Game”), to use the website (hereafter – “Website”), user account (hereafter – “Account”) and our other products (including Support Desk and forums), associated with the Game (hereafter – “Secondary resources”).
2. NAME, SURNAME AND CONTACT DETAILS OF THE DATA PROTECTION OFFICER ON BEHALF OF THE COMPANY
The data protection officer on behalf of the Limited Liability Company “ENHANCED PLAYER EXPERIENCE”
Ponomarev Evgenij Stanislavovich
3. GENERAL INFORMATION
We process data about you only in case if such processing is necessary to fulfill terms of a contract or any other agreement with you. Such processing is also necessary for observing our legal liabilities and interests, except for when other interests, basic rights and freedoms prevail over ours and demand protection of your data.
Our legal interests mean providing opportunities to use the Resources in an efficient and safe way. We strive to ensure equal conditions to everyone who uses our Resources.
3.1. YOUR PREFERENCES
By using tools in My Profile you can decide how Data concerning you will be used. Before we will follow your guidance for the use of the Data concerning you, you need to have a registered Account to access to My Profile. This means that while using a demo-version of an Account it is impossible to fully control the use of your data. To make it possible you need to acquire the full version.
For example, in My Profile you may:
- refuse of measured advertising offered via e-mail, within the Game and via Internet Network (hereafter – Network). More details in Section 7.1 “Refusal of measured advertisement and right to object”;
- acquire access to the Data concerning you. Read more details in Section 7.2 “Right of access”;
- erase your Account and the Data about you associated with it. Read more in Section 7.4. “Right to erasure/ to be forgotten”.
3.2 INFORMATION SECURITY
We and our co-workers hereby understand the necessity to ensure user confidentiality and take reasonable safeguards to prevent your personal data from loss, improper use and unauthorized access, disclosure, alteration and erasure, taking into consideration any risks related to the processing of the Personal data concerning you.
3.3 DATA PROCESSING BY THIRD PARTIES/COUNTRIES
Acting for the purposes specified herein, we may transfer the Personal data concerning you to our affiliated companies, contractors or agents working on our behalf. For example, we can involve companies to assist us in protecting and safeguarding our systems. All our contraсtors or agents shall meet our requirements to data privacy and safety; they cannot use Your personal data provided by us for any purposes other than the ones specified herein. The above mentioned companies may be situated beyond the territory of Russia and the European Economic Area. Read more in Section 6 “Transfer of personal data”.
3.4 DATA STORAGE
The majority of Your personal data collected and processed for the purposes described herein is being stored as long as you continue using our Resources (e.g. if you activated the Account of our Game). Your personal data are to be erased upon the expiry of 45 (forty-five) calendar days after you delete the Account, during these days the Account may be restored. The processing of erasure of Your personal data may last up to one month upon the termination of restoration period mentioned above, and also may be prolonged to two more months depending on the complexity of such erasure and the number of requests. Read more in Section 7.3. “Right to erasure of personal data”.
Your personal data will be stored in the Russian Federation.
For Russian users: The company organizes recording, systematizing, collection, storage, erasure (updating, alteration), retrieval of personal data of the Russian Federation citizens with the use of databases kept on the territory of the Russian Federation.
For users of the EEA or Switzerland: Russia is a jurisdiction beyond the territory of the European Economic Area which was not recognized by the European Commission as the one that can ensure adequate level of protection of personal data. Therefore Yandex took appropriate measures to ensure that such transfer will be made in accordance with the effective rules of data protection of the EU.
In particular, Yandex acts by virtue of the Standard Contractual Clauses approved by the European Commission, in order to ensure adequate level of protection of Your Personal data transferred to Russia. You can obtain the copy of these Standard Contractual Clauses upon request.
4. DATA COLLECTION
While you are using our Resources we collect data that can be obtained either directly from you (when you provide the data to us), or indirectly (e.g. via our Website or Game).
4.1 DIRECT DATA ACCESSING
We collect Your data and other voluntarily given information. The decision whether to provide the requested data shall be for you to make. You should note that the use of certain Resources may only be possible in case when you provide the necessary data (e.g. when creating an Account).
When creating an Account you may be offered to provide your personal data, including, but not limited to, name, e-mail address and your phone number.
We can also obtain Your personal data when you register and use other Resources (e.g. game forums, chats) or when you give feedback concerning our Resources. These data include:
- data that you post, as well as the one represented in comments or in a different manner, on one of the game forums and websites;
- data sent via “game chat” in the Game;
- data that you give when requesting the information or when getting assistance, or then gaining access to Resources, as well as the information necessary for processing your orders;
- additional data, apart from Account data, which you provide to us when participating in contests, tournaments, queries (e.g. contact details);
- data related to your profiles in social networks in order to ensure integration with the corresponding website.
4.2 INDIRECT DATA ACCESSING
We collect data when interacting indirectly with you via our Website. These data may include, without limitation, data on browser or device, data collected in the process of automatic electronic interaction, data concerning the app usage, demographical, geographical and location-based data, statistical and aggregated data (hereafter – “Additional data”). Statistical or aggregated data do not refer to a specific person, but can be obtained on the basis of Your data. For example, we can aggregate the Data concerning you in order to calculate the percent of users in a specific country. If Additional data is combined with Your data we shall process it pursuant to the same rules which are applicable for Your data.
4.2.1. Tracking data and cookies
Traffic volume and pattern of the website (e.g. number of website or page visitors per day) are usually referred to the category “Tracking data”. This type of indirectly obtained data is collected with the help of various means (e.g. IP address – number which is automatically given to your computer to operate on Internet). Web servers (computers which serve websites) automatically identify your computer by its IP address. When you visit our Website our servers register the IP address of your computer.
We use the following cookies of Google Analytics:
_ga (also known as _rollupGa). This cookie is used to collect data and statistics of website usage. Storage period: 2 years.
_gid (also known as _rollupGa_gid). This file allows to differentiate web users. Storage period: 24 hours.
_gat. This cookie allows to restrict the frequency of demands. Storage period: 1 minute.
_gac_. This cookie contains data about campaign for a user. Conversion tags AdWords that are available on the website obtain data from a cookie in an anonymous form. Storage period: 90 days.
_dc_gtm_. This cookie is used to file a demand in an anonymous form. Storage period: 1 minute.
We use the following cookies of Google Optimize that are needed for identifying your participation in tests, as well as for completing tests with user participation.
__utmx. Storage period: 18 months.
__utmxx. Storage period: 18 months.
_gaexp. Storage period: 90 days.
We use the following cookies of Doubleclick:
IDE and DSIS. This cookie allows to use functions of Google Analytics which are not available in standard realization. Among advertising functions are: remarketing by using Google Analytics, impression reports in Google Display Network, and such services as Google Analytics Demographics and Internet Reporting which request data collection for promotion purposes (incl. data collection with the aid of promotion cookies and identifiers). Storage period: 2 years.
Data collection and usage (cookies and IP address) can be turned off via plugin https://tools.google.com/dlpage/gaoptout.
Read more details at: http://www.google.com/analytics/terms/gb.html (Usage and confidentiality terms of Google Analytics). Note that beside Google Analytics, Google Optimize and Doubleclick in order to ensure anonymous collection of IP addresses (so-called IP masking) we use “gat._anonymizelp ();”. Besides, you can ban Google Analytics, Google Optimize and Doubleclick from collecting such data on behalf of the LLC “ENHANCED PLAYER EXPERIENCE” on: https://tools.google.com/dlpage/gaoptout.
We use the following cookies of Yandex.Metrika service:
_ym_isad. This cookie helps to monitor whether AdBlock on the browser of a user is turned on. Storage period: 24 hours.
_ym_uid. This cookie is used for collecting data and providing statistics concerning website usage. We use these cookies to add more convenience for a user. Cookies collect data (incl. information concerning the number of website visitors, the pages they visited and their location) in an anonymous form. Storage period: 2 years.
_ym_visorc. This cookie allows to display behavior. These cookies are used for the WebVisor function in the reports of Yandex.Metrika – a function that allows to “Monitor behavior”, i.e. to display visitor’s actions in video format (https://yandex.com/support/metrica/general/counter-webvisor.html). Yandex guarantees that all collected data is anonymised. Storage period: 1 day.
We also use some additional cookies of Yandex.Metrika with the following storage periods: sync_cookie_csrf – 1 day, i – 10 years, yandexuid – 10 years, yp – 10 years, sync_cookie_ok – 2 days.
In the settings of your browser you can disable the dispatch of cookies to Yandex.Metrika, collection of any data related to you can be blocked at: https://yandex.com/support/metrica/general/opt-out.html.
We use the following cookies:
enuid. This cookie is a browser identifier for counting unique feedbacks, clicks, conversion analysis. Storage period: 5 years.
enlid. This cookie makes it easier to link a visitor’s click with the consequent creation of an Account. Storage period: 30 days.
_pda – marker of the confidentiality policy acceptance.
You may change settings on your browser in such a manner as to prohibit the acceptance of third-party cookies and to notify when they are to be sent. Detailed instructions can be found in the browser instruction.
4.2.2. Data associated with Games, device information, geolocation data
In order to give you the opportunity to use the Resources in a proper way we need to collect, store and use various data concerning Your actions in Games. “Data associated with Games” includes an identifier of your User account, and also game statistics. Game statistics – information about your preferences in Games, progress in Games, participation in clans, play frequency, and information about the device, with the help of which you use the Resources, including the type of the device, its operational system, parameters, unique identifiers and error data. The type of the device and its settings make difference to whether the data is collected wholly or partially. The data concerning precise location (GPS/ GLONASS) of mobile phone are collected upon your permission. In order to identify approximate location Wi-Fi and IP address of your device can be used.
4.2.3. Data for fraud and violation detection
We also collect certain data (e.g. IP address, user name etc.) to detect, investigate and avert any violation of the rules of the Game and the License Agreement of an end user. These data are used only for the purposes mentioned above and are deleted twelve months after being collected, unless the proving of violation needs more time. When the data can be used to prove the fact of fraud or other form of cheating, violation of the terms and conditions of the License Agreement of an end user, we keep these data for submission, support or claim protection during the applicable period of limitation of such claims.
4.2.4. Data from common access online-resources
In order to fulfill our liability pursuant to the License Agreement of an end user, and in case if the data processing is required in order to fulfill a legal liability, we may obtain data concerning you from our partners (namely, payment and advertising partners). We use the data only controlled by our partners in accordance with their instructions and applicable legislation. When you buy virtual goods or premium membership restricted in terms via your credit/debit card, we can obtain from our payment partners and process a part of your credit card number, information about the emitter of your credit card, and full address in order to prepare bills.
5. DATA USAGE
Performance of the agreement with you pursuant to Article 6(1)(b) of the General Data Protection Regulation requires processing of your personal data. Unless otherwise stipulated by law Your data will be used for the following purposes:
- provision of the opportunity to use the requested Resources;
- observation of liabilities set by law
- furnishing data concerning the Account, transactions, functions of our Website and updates in our policies to a user;
- rendering support (incl. but not limited to, product update, troubleshooting etc.);
- keeping the user informed regarding the Game (incl. market launch date), announcements, reviews, commentaries, tests etc.
We use your data in our legal interests pursuant to Article 6(1)(f) of the General Data Protection Regulation in order to notify you of the peculiarities of our Website, to provide data on new product launch, and to promote our products in compliance with the effective Policy. Therefore as soon as you create an Account, we will be able to use your e-mail address, nickname, IP address, mobile phone number in order to send you e-mails, messages and measured advertising of the Game (both within the Game and via Network). Besides, is you subscribe for mail-outs, we can send you e-mails, messages and measured advertising (whether within the game, via e-mail or via Internet Network) concerning events, joint projects of the Company and its partners.
5.2. IMPROVEMENT OF THE QUALITY OF SERVICE
We analyze Tracking data, Content data and Data associated with Games to determine how we can improve the quality of service of our players. You have the right not to participate in surveys and choose what information to provide.
6. DATA TRANSFER
In order to fulfill the terms of the agreement with you and to observe our legal liabilities and interests we can transfer Your personal data to third parties of the following categories:
- Payment partners: we provide them your e-mail address, IP address, information on purchases in the Game requested by you on the Company’s Website, and other information that you give for us when registering purchase;
- Advertising partners: we provide them your e-mail address, nickname, IP address and other data given by you and which allow to simplify the transfer of online advertisement of third-party services and in a different way to help to transfer information that can be useful, relevant or interesting for you;
- Data storage partners: some data are stored on the servers of third-party data storage services; this way, your answers to the majority of in-game queries are stored on the servers of the Company, and some data of the game statistics – on servers of LLC “Single Network”;
- Research partners: we can provide access to some of Your data (e.g. game statistics) to carry out marketing and other researches. We report anonymous data to our partners in case when the Data concerning you for providing access to the requested Resources or researches are not necessary;
- User support partners: on some territories and in relation to certain products we involve third parties to provide user support for you. Such companies may obtain access to Your personal data which you provide when making a support request.
- Common access information: our Website and Game can also have announcement desks, forums and/or chats where users can exchange ideas and communicate with each other. When posting a message on the desk, forum or in the chat zone, note that the information will be publicly available in online mode. Therefore you post it at your own peril and risk. If one of our forums has posts with your data, use the tools in My Profile to request their erasure.
- External moderators and testers: some of your data (nickname, support ticket data) can be available for third-party voluntary moderators and testers that help to increase the quality of the Resources (e.g. increase the rate speed when answering to your questions concerning the Game);
- Fraud prevention companies: we can disclose the data necessary for detecting, investigating and averting any violation of the rules of the Game and the License Agreement of an end user, only for the purposes mentioned above;
- Transfer of control: we can disclose Your data when selling, amalgamating or changing the control structure of our company, and when preparing to any of these events. Any party that buys the company or its part shall obtain the right to use Your data, but only in accordance with the present Confidentiality Policy, unless otherwise agreed by you.
If the Data concerning you are disclosed to third parties beyond Russia or the European Union the Company guarantees a proper level of protection of the Data concerning you, including, but not limited to, implementation by third parties of standard provisions of the European Commission on data protection. We will provide a copy of the standard provisions of the European Commission on data protection upon your request.
Disclosure of anonymous data. We can also disclose to our advertising partners anonymous data (i.e. data that do not disclose your identity nor directly neither indirectly), and aggregated data (data on user groups and categories, incl. game statistics and data on game behavior which do not identify a certain user and cannot be used for such identifying). We can also permit some of our advertising clients to collect anonymous and aggregated data within the frame of providing opportunity to use the Resources, and thereafter they can transfer it to us. Our advertising clients can collect data with the help of tracking technologies (e.g. cookies and web beacons). These technologies allow our advertising clients to develop and run advertisements as a matter of using the Resources and on websites of third parties, and to give you advertisement of products that can catch your interest. The advertising clients also use these data for monitoring and developing their own activity.
7. YOUR RIGHTS
When using a demo-version of an Account your data usage cannot be fully controlled, it is possible only after the Account is upgraded to a full version. By utilizing tools available in My Profile you can subscribe to various types of direct communication, and exercise your rights to access data, erase it and ban it from processing.
7.1. REFUSAL OF MEASURED ADVERTISEMENT AND RIGHT TO OBJECT
You can control your subscriptions to measured advertisement when creating an Account and further via My Profile. Take a note that even if you cancel subscription we nevertheless will be able to send you some notifications (so called “transactional notifications”), for example, to confirm a purchase or changes in your Account, to provide information on guarantee and safety, amendments in the License Agreement of an end user and the Confidentiality Policy. Emailing of all notifications shall terminate after the Account is deleted.
If the processing of your data is based on legal interests you can exercise your right to object to such processing at any time. In this case in the absence of convincing legal causes for data processing or when are not needed for submission, support of protection against claims, we shall terminate the data processing.
7.2. RIGHT TO ACCESS
You shall have the right to access the data concerning you received by us, i.e. you shall have the right to request free delivery of (i) information about storage of the Data concerning you, (ii) access to the Data concerning you, and (iii) copies of the stored Data concerning you. You can exercise the right to access the Data concerning you by directing a corresponding request to the Company.
7.3. RIGHT TO ALTER THE DATA
It shall be your right to choose which nickname, email address, phone number, country, social media accounts, proxy websites and methods of payment will be associated with Your Account. If any data is altered you need to update the Account correspondingly. Contact us if any data about you contradict the reality.
7.4. RIGHT TO ERASE THE DATA
You shall have the right to request the erasure of the Data concerning you by deleting Your Account via My Profile. As a result of deleting your account you will lose access to the majority of Resources, including access to the information connected to Your Account concerning the Account and the Game, subscriptions to forums, and other Resources, for which the Account was designed.
Period of restoration. We give you the opportunity to restore your Account within the period of restoration that is 45 (forty-five) days after sending a deletion request. This allows to save the data about the Game, other important settings and error information. The period of restoration allows to finish financial and other transactions which you could have initiated before sending a deletion request.
Erasing the Data concerning you without deleting the Account. We store the majority of the Data concerning you even subject to the absence of a deletion request of the Account created via My Profile. Nonetheless some Data concerning you can be erased when the Account is in effect. Therefore, the following data can be deleted:
- Data concerning you which we collected during queries, opinion analysis published on YouTube, Facebook, vk.com (within the period of creation of reports for increasing the quality of the Resources and the next 30 (thirty) days);
- Technical logs – access logs, error logs (specifically within 30 (thirty) days after creation).
Data storage. Upon termination of the period of restoration of a User account we will delete all your data, except for the data that are necessary for fulfilling requests of the applicable legislation (e.g. regarding taxation and accounting), and for detecting, investigating and averting any violation of the rules of the Game and the License Agreement of an end user. After deleting Your Account the anonymous data is also restored. After deleting your account or the information in the User Account or in electronic mailbox the information that you posted e.g. in the Game chat of in forums remains; in addition, we do not control the data copied by other users. In groups the source of a content connected to a closed Account is defined as an unknown user. Your profile may continue showing up in other services (e.g. in search results) until the updating of corresponding cache memory.
You shall also have the right to file a complaint to supervisory authority.
8. WE RESERVE THE RIGHT TO AMEND THE PRESENT CONFIDENTIALITY POLICY
We shall have the right to periodically for different reasons amend the present Policy, for example, when we need to show the amendments in the legislation and statutory regulations, industrial principles and engineering developments. When amending the headline of the Policy the date of the latest update is specified. The updated version of the Policy shall enter into force when posted on the website, unless otherwise provided by the updated version of the Policy.