RoboHero PRIVACY POLICY
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Last revised and effective: 18 December 2022
IMPORTANT NOTICE: PLEASE READ THIS DOCUMENT CAREFULLY BEFORE
ACCEPTING, AND MAKE SURE YOU HAVE REACHED THE AGE OF 16 OR
WHICHEVER OTHER AGE MAY BE REQUIRED TO ACCEPT THIS POLICY IN
ACCORDANCE WITH THE LAWS OF YOUR COUNTRY OF RESIDENCE. YOU
CAN FIND OUT MORE DETAILS ABOUT PERMISSIBLE AGE IN SECTION 12
BELOW. ENGLISH VERSION OF THIS POLICY IS THE ONLY ORIGINAL
VERSION AND SHALL PREVAIL IN THE EVENT OF ANY DIFFERENCES,
QUESTIONS OR DISPUTES CONCERNING THE MEANING, FORM, VALIDITY OR
INTERPRETATION THEREOF.
This Privacy Policy constitutes an integral part of the Terms and Conditions as defied
in Terms of Service current version of which available at:
https://robohero.io/assets/bt-terms - and explains the details of processing the
personal information (“data”) about you as a user of our services (“services”,
“RoboHero services” or “our services”, taking into consideration the context),
including:
● Mobile games being distributed by RoboHero directly (explicitly excluding, for
avoidance of doubt, distribution via any third-party gaming platforms such as,
Nintendo, Google Play Store, Apple App Store, Nintendo Game Store and
etc.);
● Any other RoboHero services provided under the Terms and Conditions
(computer and mobile applications, websites, forums, online store,
marketplace, any support services, including RoboHero Support Service, and
etc.) –
and/or as a registrar and consequent holder of a user account within our services
which is unified for all RoboHero services (“RoboHero Account”).
IN SHORT: in order to provide you with our services, we need to collect and then
process some of your data which we define below. We also need do share some of
such data with our partners and other third parties in order to make it possible. We
will not disclose any of your data otherwise than provided by this Privacy Policy. We
ensure security of your data while processed by us. By accepting this Privacy Policy,
you give us your explicit consent to process your data in accordance with the rules of
this document.
This Privacy Policy is split in the following sections for your comfort:
1. WE AS DATA CONTROLLER
2. WHAT DATA WE PROCESS
3. FOR WHAT PURPOSE WE PROCESS YOUR DATA
4. HOW LONG WE STORE YOUR DATA
5. WITH WHOM WE SHARE YOUR DATA
6. WHAT ARE YOUR DATA PROCESSING RIGHTS
7. WHAT ARE YOUR DIRECT MARKETING RIGHTS
8. WHAT IS OPT-OUT OPPORTUNITY
9. HOW AUTOMATED DECISION-MAKING APPLIES TO YOU
10.HOW WE SECURE YOUR DATA
11. HOW TO WITHDRAW YOUR CONSENT
12.HOW WE TREAT CHILDREN’S DATA
13.HOW WE PROCESS YOUR COOKIES
14.HOW WE UPDATE THIS PRIVACY POLICY
15.HOW TO CONTACT US
This Privacy Policy does not apply to any personal data collected from job
applicants.
1. WE AS DATA CONTROLLER
We process your data according to the terms and conditions of this Privacy Policy as
data controller.
The term “data controller” refers to the legal entity which determines the purposes
and means of the processing of your data.
Data controller: one of the following legal entities (depending on the circumstances
described right below):
● When services are provided directly to the user (e.g. via our web-sites):
DevDream House OÜ, with its registered address at Harju maakond, Tallinn,
Lasnamäe linnaosa, Lõõtsa tn 5, 11415
● When services are provided via third-party platforms (e.g. GameSwift,
Nintendo, Google Play Store, Apple App Store): DevDream House OÜ Harju
maakond, Tallinn, Lasnamäe linnaosa, Lõõtsa tn 5, 11415.
Email: [email protected]
In this Privacy Policy “data controller”, “RoboHero”, “we” or “our” mean the same
subject.
2. WHAT DATA WE PROCESS
2.1. The data below may be provided by different sources, including you (whether
intentionally or automatically through the use of our services), our affiliates on our
request, and our partners (as described in Section 5 below), or may be generated by
us on the basis of the aforementioned data.
2.2. Under the terms and conditions of this Privacy Policy we process the following
types of data about you which are accompanied with examples of such data (sample
data for reference) and primary sources of such data (source):
Type of data
Sample data for reference
Source
1.
Personality
data
Nickname, age (mostly age
range), gender and other data
about your person we may be
provided by you (at your own
discretion) or our partners
provided they have a valid lawful
basis for that (e.g. your consent)
You
(intentionally),
our affiliates and
partners
2.
Identity data
Real name, date of birth, age,
gender, ID, Tax/VAT number, scan
of ID, passport or another
identifying document, tax
certificate or any document issued
by state authorities, photo or
video recording with you, clothing
size and other data about your
identity as an individual which
may be necessary for a particular
purpose designated herein
You
(intentionally)
3.
Contact data
Contact e-mail, recovery e-mail,
mobile phone number, residential
address, shipping address, social
network ID, parent or legal
You
(intentionally),
our affiliates
guardian/representative contact
details
4.
Localization
data
IP address and related
geolocation data (city and
country), language preferences
You (both
intentionally or
automatically),
our affiliates and
partners
5.
Account data
Your User ID (which is generated
by us), login name, password (for
verifying you while singing-in),
nickname, avatar (profile photo),
e-mail, registration date and time,
our games you play, list of your
purchases, gifts, balance, any
other data you may leave within
your RoboHero Account
You (both
intentionally or
automatically),
our affiliates and
partners
6.
User generated
content (UGC)
data
Any data submitted in forums,
messages, chats, etc. by the user
of their own choice, other than
Submissions data. Depending on
the services and place of posting
(chat room or forum), this
information can be available to
some or all other users of our
services
You (both
intentionally or
automatically)
7.
Data regarding
your requests
or other
submissions to
us
(“Submissions
data”)
Your feedback, comments,
answers to questionnaires,
opinions and other submissions
with regard to our services form of
texts, screenshots, audio or video
recordings
You
(intentionally)
8.
Data about
your behavioral
actions when
using our
services
(“Behavioral
data”)
Information about the way you
use our services, its frequency
and etc. (e.g. log-ins, services
segments used, page views,
transactions made within our
services) other than Browsing
data and Gameplay data
You
(automatically),
our affiliates and
partners, or
generated by us
9.
Data about
your browsing
behavior and
your identity on
the Internet
(“Browsing
data”)
Cookie files (more details are
available in our Cookies Policy),
Your IP address, name of your
browser, name of your Internet
provider, traffic source (including
the source from which our games
or apps were installed on your
device)
You
(automatically),
our affiliates and
partners, or
generated by us
10.
Gameplay data
Any data about your in-game
actions in tangible (including
electronic) form, data about your
in-game interactions with other
players, duration of your gaming
sessions, data about choices
made within gameplay
You
(automatically)
our affiliates, or
generated by us
11.
Game data
Game version, installation date
and time, graphics, audio and
other game settings, game
achievements, progress and
inventory, other in-game results,
last launch date and time and etc.
You
(automatically),
our affiliates
12.
Data about
your device(s)
(“Device data”)
Device ID, MAC address, location
data (city and country), language
settings, time zone and
localization settings, device
manufacturer and model,
operating system, installed
applications, phone network
operator, network type and
connection, Internet connection
speed, screen resolution and
orientation, device hardware
characteristics (CPU, GPU, RAM
and ROM size, battery etc.) and
other software and hardware
information about your device
You
(automatically),
our affiliates and
partners
13.
Customer
service data
Case details, case history,
complaint history, customer
service chat logs, penalties
history, any submitted files and
information
You
(intentionally),
our affiliates
14.
Purchase data
Name and cost of purchased
in-game items, total cost of
purchased in-game items, total
amount of spent, amount in-game
currency you possess or spent
You
(automatically),
our affiliates and
partners
15.
Third-party
services data
(e.g. Google
Play Account,
Nintendo,
Apple App
Store)
Nickname (on third party
platform), User ID, including social
network IDs and application store
IDs, e-mail, any types of identifier
for advertisers (IDFA, such as
Apple IDFA and Google AAID)
and other data necessary for your
registering in our services via your
social or application store
accounts and/or connecting your
social account to our
services/RoboHero Account (e.g.
Facebook, Twitter)
You
(automatically),
our affiliates and
partners
16.
Analytical data
Any information derived from the
data mentioned in this table
(except identity data) used for
analytics, including retrieving
in-game, marketing, advertising or
other statistics
Generated by us
2.3. In case we need to process another data about you, we will request a separate
approval for such data processing from you.
2.4. Please note that we DO NOT INTENTIONALLY process any special categories
of personal data (including any information about your health, race, religion, political
views, etc.). We kindly recommend you remain cautious when sharing this data
about yourself when using our services, in game chats, on the websites (forums,
commentaries, etc.) and otherwise on the Internet.
3. FOR WHAT PURPOSE WE PROCESS YOUR DATA
3.1. We process your data as we aim at providing you our services in the best
possible manner and the highest level of service, efficiency and your convenience,
and, in some cases, to make the mere provision of such services possible, including
from the technical prospective. The data processed by RoboHero according to this
Privacy Policy can only be used for the following purposes (processing purpose)
which are accompanied with the examples of particular situations when your data is
being used (purpose examples), the data used for such purposes (data processed)
and lawful basis for processing such data for respective purpose (lawful basis for
processing):
Processing
purpose
Purpose
examples
Data processed
Lawful
basis for
processing
1.
Providing
the basic
services
under the
Terms and
Conditions
Operating and
supporting our
services
Creating user
profiles, maintain
the users
database
Enabling you to
communicate
with other
players in chats
and on forums
Personality data
Localization data
Account data
UGC data
Behavioral data
Browsing data
Device data
Game data
Gameplay data
Purchase data
Contract
performance
Consent
(additionally)
Analytical data
Third-party services
data
2.
Personalizin
g our
services for
you
Storing your
preferences and
settings
Personality data
Localization data
Account data
UGC data
Submissions data
Behavioral data
Browsing data
Device data
Game data
Gameplay data
Customer service
data
Purchase data
Analytical data
Third-party services
data
Consent
3.
Verifying
your identity
and your will
Verifying your
logging-in
Verifying your
will to make a
purchase within
our service
Verifying your
will to commit
other actions
within our
service
Identity data
Contact data
Third-party services
data
Contract
performance
Legitimate
interest
Consent
(additionally)
4.
Enhancing
our services
and your
user
experience
Enhancing our
games and other
services,
creating and
developing new
ones
Linking your
RoboHero
Account to your
third-party
accounts
(including Apple
App Store,
Google Play
Store, Nintendo)
Any data excepting:
●Identity data
●Contact data
Consent
Bugs fixing and
other
troubleshooting
Conducting
services-related
business
optimizations
5.
Organizing
the work of
customer
support
service
Receiving and
responding your
inquiries and
requests
Fulfilling your
inquiries and
requests with
regard to our
services
Providing you
with other
support services
in connection
with our services
Maintaining
proper
functioning of our
customer
support service
Any data required
for response to
user’s request
Contract
performance
Consent
(additionally)
6.
Creating and
utilizing
analytics on
our services
and
audience
Analyzing your
activity while
using our
services (e.g.
web-sites)
Improving our
services
according to the
analytics
collected
Utilizing the
analytics
collected for
commercial
promotion of our
services and
other
advertisement/m
arketing
purposes
Any data excepting:
●Identity data
●Contact data
Consent
7.
Conducting
advertising
and
marketing
activity
Communicating
users about
discounts and
promotions with
respect to the
services
Serving
advertisement
relevant to you
Conducting
quizzes,
contests,
competitions,
awards and
other promo
events
Sending
newsletters
(including about
patches and
updates, news,
forthcoming
releases, special
promotions and
competitions,
and other events
directly related to
our services) and
marketing
Personality data
Localization data
Account data
Behavioral data
Browsing data
Device data
Gameplay data
Purchase data
Analytical data
Third-party services
data
Consent
materials to you
relating to our
services
Informing you
about our offers
(discounts,
in-game offers
and other
relating to our
services) which
may be
interesting
specially for you
Conducting our
own advertising
campaign of
RoboHero
products or
services, using
the data for other
internal
marketing
purposes (or
other marketing
purposes related
to the services)
8.
Securing
your user
experience
Fighting frauds
(such as
cheating,
tampering,
unauthorized
transactions and
other unfair
methods of play),
including by
means of players
behavior
analyses,
banning players
and taking any
necessary
precautions
measures
Personality data
Account data
UGC data
Submissions data
Behavioral data
Device data
Game data
Gameplay data
Customer service
data
Third-party services
data
Consent
Legitimate
interest
(additionally)
9.
Conduct
surveys and
research
Organizing
questionnaires
with regard to
our services
Receiving
feedbacks from
you
Personality data
Localization data
Account data
Behavioral data
Browsing data
Device data
Game data
Gameplay data
Purchase data
Analytical data
Third-party services
data
Consent
10
.
Enabling
purchase
opportunities
within our
services
Verifying and
confirming your
payments
Sending you
respective
invoices
Transferring
funds (e.g.
purchased
in-game items)
to your
RoboHero
Account
Personality data
Identity data
Contact data
Account data
Purchase data
Third-party services
data
Contract
performance
Consent
(additionally)
11.
Providing
security of
our services
and integrity
of our
business
Preventing (and
fighting)
violations of the
Terms and
Conditions
Preventing
infringement of
our intellectual
property and
other rights
Any data
Legitimate
interest
12
.
Compliance
with our
legal
obligations
imposed by
applicable
laws
Compliance with
any applicable
privacy laws and
regulations
(GDPR, COPPA
and etc.), tax or
accounting rules,
know-your-custo
mer,
anti-laundering
and other laws
RoboHero have
an obligation to
comply with
Any data
Legal
obligation
13
.
Contacting
you on other
matters
Contacting you
with regard our
services on the
matters
described in this
table earlier
Any data
Contract
performance
Legitimate
interest
Consent
(additionally)
For your convenience we explained the meaning of each lawful basis used in the
table above:
● Consent - your data is processed after receiving from you a freely given,
specific, informed and unambiguous consent for that. To ensure security of
your privacy laws rights, we may additionally request your consent for
processing your data on other lawful basis (e.g. contract performance or
legitimate interest), however, we also draw your attention that the withdrawal
of such consent does not preclude us to process your data if such processing
is permitted by applicable law on the other basis (including those mentioned
right below).
● Contract performance - your data is processed when necessary to perform a
contract with you, such as the Terms and Conditions, or to take necessary
steps for contracting you if you request that.
● Legal obligation - your data is processed when (and in the manner) required
by applicable laws.
● Legitimate Interest - your data is processed in order to comply with our
legitimate interests (such as preventing violations of our intellectual property
and other rights), or legitimate interest of other party (including you), when
these interests outweigh your own rights and interests.
3.2. In case we need to process your data for another purposes, we will request a
separate approval for such purposes from you.
3.3. We specifically draw your attention that RoboHero may also use your data for
creating anonymized databases (including any compilations, lookalike models and
etc.) which will be further utilized by us (or any third party upon our authorization) for
any purpose, including our internal ones. We guarantee such databases will not
contain any data which could be used for identifying you (personal identifiable
information), despite the fact such data will be derived from your personal data and
the data of other users. Likewise, we can also use your data in anonymized form,
e.g. by the compilation other than described above, in the way it does not constitute
your personal data after anonymizing/compilating. Before anonymizing, your data is
used strictly as set forth in this Privacy Policy.
4. HOW LONG WE STORE YOUR DATA
4.1. We retain any of your personal data which we collect for as long as your
RoboHero Account is active according to the Terms and Conditions, and/or for as
long as it is necessary to provide you with the services, and while we have a valid
lawful basis for processing your data. We also erase your personal data after
reaching the purposes for which we collected such data.
4.2. Please consider that we have the right to continue to retain some of your user
data even after complying with your request to delete such data in the following
cases:
● We have the lawful basis to further process your data other than a consent
from you. As instance, we may be required to do so in order to comply with
applicable laws (as instance, for tax or accounting reasons,
know-your-customer, anti-laundering or other legal requirements and
obligations);
● Your user data has been anonymized in the way it cannot be used for
identifying you, and therefore is no longer your personal identifiable data.
5. WITH WHOM WE SHARE YOUR DATA
5.1. For the purposes of processing your data under this Privacy Policy RoboHero
may share your data with third parties. In order to make you know about your data
flow and possible transfers, we prepared the following table where we have
described which categories of recipient we usually transfer your data to (category of
recipient), which our main partners, as an example, comprise such categories or
which our counterparts may be qualified for such categories (partner examples or
explanation), for which purpose, as defined in Section 3, we share your data with
such third parties (share purpose) and which lawful basis, as defined in Section 3,
we invoke for the transfer (lawful basis for transfer):
Category of
recipient
Partner
examples or
explanation
Share purpose
Lawful basis
for transfer
1.
Analytics
partners
Google
Analytics,
Yandex Metrics
Creating and
utilizing analytics
on our services
and audience
Conducting
advertising and
marketing
activity
Conduct surveys
and research
Personalizing
our services for
you
Enhancing our
services and
your user
experience
Traffic analysis
Consent
2.
Tracking,
analytics and
statistics
partners
CloudFlare,
Facebook,
Amazon AWS
Consent
3.
Advertising
partners
WeMakeIt
Conducting
advertising and
marketing
activity
Personalizing
our services for
you
Consent
4.
Operating
partners
Amazon AWS
Providing the
basic services
under the Terms
and Conditions
(as instance,
Amazon Web
Services are
used, among
others, for
hosting our
servers)
Consent
6.
Two Factor
Authentication
services
Google
Authenticator
Verifying your
identity and your
will
Consent
8.
Assignees
Any assignee of
our rights and
obligations under
the Terms and
Conditions
Any purpose
Legitimate
interest
Consent
(additionally)
9.
Auditors and
other
examination
organizations
Any entity
conducting audit
or other
legal/financial
check of
RoboHero
Compliance with
our legal
obligations
imposed by
applicable laws
(in certain cases
provided by law)
Legitimate
interest
Legal
obligation (in
certain cases
provided by
law)
Consent
(additionally)
10
.
Our affiliates
Any legal entity
affiliated to
RoboHero
Any purpose,
mainly:
●Providing
the basic
services
under the
Terms
and
Condition
s
●Organizin
g the work
of
customer
Legitimate
interest
Consent
(additionally)
support
service
11.
Government,
regulatory,
judicial,
enforcement
or other state
authorities
Data protection
authority,
governmental
trade
commission,
police, court,
bailiffs and etc.
Compliance with
our legal
obligations
imposed by
applicable laws
Legal
obligation
5.2. As a rule, we do not share your data with anyone other than specified in the
table above, and we ensure the confidentiality of your data. However, in some cases
we may be obliged to provide other third parties with your data if such obligation is
imposed on us by applicable law.
Processing your data by our partners
5.3. Usually our partners determine the principles and purposes of user data
processing by themselves. It means that the processing of your data by them is not
covered by this Privacy Policy and is done in accordance with rules imposed by such
partners.
5.4. For your convenience we prepared the list of our main partners to whom we
usually disclose user data and the list of their respective privacy policies. Please
note that this list is not exhaustive and does not cover all our partners (only main
ones), and some of the policies below may be not applicable to your region, please
make sure that the privacy police you read applies to your country of residence):
Partner
Privacy Policy available at
Google
https://policies.google.com/privacy?hl=en-US
Facebook
https://www.facebook.com/policy.php
Amazon AWS
https://aws.amazon.com/privacy
CloudFlare
https://www.cloudflare.com/privacypolicy
Yandex Metrica
https://metrica.yandex.com/about/info/privacy-policy
5.5. Despite we indicate the payment data as to be processed by us, for your better
understanding the data amount we process about you, we DO NOT anyhow save or
store your payment data at any period of time. Such data is de facto collected and
further processed by our payment partners; we only provide them with the technical
opportunities to do so through within our services. As such partners commonly do
not have any general privacy policy unified for all regions, we recommend you to
access and read out the relevant documents while making a payment via their
platforms (e.g. after you have been redirected by our services to the website of a
relevant platform when initiated the payment procedure).
5.6. We may share your user data with any competent law enforcement body, or
regulatory or government agency, or with the courts for the purposes of compliance
with applicable legislation, or in response to an official and legal request.
5.7. In the future, we may enter into contracts with other partners. If this is the case
then we will make every reasonable effort to update the list of our partners (as well
as the links to partners' privacy policies in clause 5.4) which is provided in this
Privacy Policy in a timely manner, but in any way no later than once every six
months, or more often in the event of a significant change in our data processing
practices.
Transferring your data abroad
5.8. We operate all over the world, and therefore we may transfer your data to our
counterparties (partners, affiliates and etc.) in different countries, including those
which are located outside the European Economic Area (EEA). We do all our efforts,
including those imposed on us by applicable law, to ensure an adequate level of
personal data protection in each case, HOWEVER, we would like you to consider
that the countries to which we transfer your data may not have the same data
protection laws as your jurisdiction.
5.9. We take all reasonable steps to ensure the confidentiality of your personal data
when it is transferred abroad, including to the countries which are located outside the
European Economic Area. We will also take reasonable steps to assure that third
parties to whom we transfer any personal information will provide sufficient
protection of your data. In particular, RoboHero undertakes reasonable physical,
technical and administrative security measures to ensure your data is adequately
protected, including when it is transferred to countries which are located outside the
European Union or European Economic Area: such measures include (without
limitation) executing standard contractual clauses which have been adopted by the
European Commission, when transferring your data to the third parties located
outside the European Economic Area.
Your data and other users
5.10. Please note that other users of our services may see some of your data we
process. For example, other users are able to see your nickname and avatar (profile
photo) and the data of your linked accounts (including Google Play Store, Apple App
Store, Nintendo accounts). They can also see any content you post publicly within
our services (public messages on forums, attached files and etc.), or some of your
game results (data of in-game ratings or leaderboards) and achievements.
6. WHAT ARE YOUR DATA PROCESSING RIGHTS
6.1. Taking into consideration the differences in data protection laws which may be
applicable to you by virtue of your citizenship, residence and other factors, usually
data protection laws (such as GDPR) grant the data subject (you) the following data
protection right which are applicable to this Privacy Policy and your data processing
by RoboHero as well:
Your right
Right explanation
1.
Right to access
You have the right to request the copy of your data
processed by RoboHero
2.
Right to
rectification
You have the right to request that we correct any
information you believe is inaccurate, incomplete,
outdated, incorrect, unlawfully received or no longer
relevant for the purpose of processing
3.
Right to restrict
processing
You have the right to restrict the use of your data in
certain circumstances entirely or in part where
possible, unless we have an opposite obligation
required by applicable law
4.
Right to erasure
(“right to be
forgotten”)
You can request RoboHero to erase any of your data
unless we have an opposite obligation required by
applicable law
5.
Right to
portability
You have the right to receive your data in a structured,
commonly used and machine-readable format or to
request RoboHero to directly transmit those data to a
third party where technical possible and reasonable
6.
Right to object to
processing
You have the right to object to the processing of your
personal data
7.
Other rights
You may have other rights in accordance with this
Privacy Policy and applicable laws
How to exercises your data protection rights:
6.2. In order to exercise your data processing rights stated in clauses 1-5 of the table
above, you should send us a request via our support service:
[email protected], and follow the instructions provided or send us such a
request directly through your RoboHero Account settings (where available). Other
requests concerning your data processing rights can be sent to
6.3. Please note that in some cases, in order to comply with a request, we may ask
you to provide us with some additional information where this is necessary to identify
you as our user. We undertake to comply with your request free of additional charge
within one month of receipt, but in some cases this period may be extended by a
further two months. We have the right to refuse to comply with your request or
charge a reasonable fee if your request is manifestly unfounded or excessive.
6.4. Please note that complying with your request to restrict processing or to erase
your personal data may result in the deletion of your RoboHero Account (including all
game results, and any game progress which is associated with your RoboHero
Account which will be may be irretrievably lost), so please consider this when
deciding to exercise these personal data rights.
6.5. Please also note that uninstalling our game (or any application related to our
services) from your device does not automatically result in the erasure of your
personal data from our servers.
6.6. We would like to draw your attention on the fact that some of the
aforementioned rights may have some limitations in terms of their exercising due to
obligations imposed on RoboHero by applicable laws. As instance, in some cases
we have to archive your data and continue to store it for a certain period of time
(which depends on the requirements set forth by applicable law) even after you
requested full erasure of such data.
How to protect your data processing rights:
6.7. As a rule, each country (as instance member-states of European Union)
provides at least one independent public authority (supervisory authority) which is
responsible for enforcing local data protection laws and protecting personal data
rights of natural persons. If you believe RoboHero violates your data protection
rights, you may lodge a complaint with a supervisory authority, in particular in the
country of your habitual residence, place of work or place where the violation
occurred. However, we would like to encourage you to contact RoboHero first, so we
could promptly review your complaint, eliminate the violation, if any, and restore your
rights. In such case please let us know at: [email protected]
7. WHAT ARE YOUR DIRECT MARKETING RIGHTS
7.1. As RoboHero has the right to send you direct marketing messages or e-mails
(as we described in clause 3.1.7 of this document), we additionally draw your
attention that you have the right to unsubscribe from each of such mailings by
exercising your opt-out rights as specified in the Section 8 of this Privacy Policy
below.
7.2. Please note that your refusal to receive direct marketing messages from us does
not affect our right to send you other messages, emails or otherwise contact you as
allowed by virtue of this Privacy Policy.
8. WHAT IS OPT-OUT OPPORTUNITY
8.1. If you wish to opt-out the processing of your data with regard to certain
purposes, including the purposes of direct marketing, you should send us a request
consider that opting-out certain processing purposes may lead to impossibility of
providing you our certain (or even all) services in part (or at all). We will take our best
efforts to minimize such services limitations.
8.2. Please take into consideration that the opt-out opportunity applies only to the
processing of your data based on your consent, unless otherwise is explicitly stated
by the applicable law. We still have the right to process your data based on the other
lawful basis such as contract performance, legitimate interest or legal obligation, if
available by virtue of applicable law, even if you have opted out such processing
according to the provisions of this Privacy Policy section, however, in this case you
are still able to exercise your right to object, as described in Section 6 above, at any
time.
Opt-out opportunities for California and Nevada residents
8.3. Despite RoboHero did not sell (but could share in accordance with Section 5
above) your data in the last 12 months, we would like to inform you that both
California and Nevada state grant its residents the following opt-out rights:
8.3.1. California residents using our services have the right to opt out the disclosure
of their personal data to third parties for direct marketing purposes. If you would like
to exercise this right you should contacting us at: [email protected].
8.3.2. Nevada residents using our Services have the right to opt out the sale of
covered information for monetary consideration. “Sale” and “covered information”
shall be defined according to Nevada laws. For the purposes of your convenience,
we inform you that on the effective date of this Privacy Policy the “Covered
information” includes your first name, last name, address, email address, phone
number and any identifiers allowing a to contact you by means of physical
communication or online. If you would like to exercise this right you should
contacting us at: [email protected]
8.4. For a list of the categories of personal data we have shared for commercial
purposes during the last 12 months, please contact us at: [email protected].
Push notifications
8.5. Some of our services (as instance, mobile games or application) may send push
notifications to your mobile device for the purposes prescribed by this Privacy Policy
with regard to messages or e-mails. Usually you can manage push notifications in
“settings” section of your device.
9. HOW AUTOMATED DECISION-MAKING APPLIES
TO YOU
9.1. RoboHero itself do not use your data for profiling or other means of automated
decision-making that could affect your legal situation (including your access to the
services or other rights under the Terms and Conditions).
9.2. However, some of our partners as described in Section 5 of this Privacy Policy
may apply automated decision-making while processing the data, we shared
according to Section 5 above (as instance, for the anti-cheat and unfair play
prevention purposes).
10. HOW WE SECURE YOUR DATA
10.1. We are constantly working on creation, improvement and further
implementation of both administrative (for example, as described in clause 5.9 of this
Privacy Policy) and technical measures for securing your data from any unauthorized
actions which can be carried out by third parties or occur incidentally, such as
unauthorized access, disclosure, alteration, destruction or other malicious use of
your data, as well as incidental loss or corruption of such data. We undertake all
reasonable steps and measures which are necessary to ensure your data is treated
securely and in accordance with this Privacy Policy.
10.2. Please consider that we maintain some of our servers, where we store your
data, and the databases containing your data outside the European Economic Area,
and most likely, outside the country of your residence.
11. HOW TO WITHDRAW YOUR CONSENT
11.1. You are entitled to withdraw your consent to process your data under this
Privacy Policy at any time by initiating the deletion of your RoboHero Account
through your account settings and following the instructions provided by RoboHero
after your sending such a deletion request. If you wish to withdraw your consent in
respect of a particular processing purpose, please contact us at
[email protected]. However, we reserve the right to cease providing you the
services if your withdrawal is not consistent with providing services in the manner
prescribed by the Terms and Conditions. Please note that such withdrawal does not
have any impact on the validity of the consent before withdraw and we reserve the
right to process your data on other lawful basis if permitted by applicable law.
11.2. Please also note that uninstalling our game (or any application related to our
services) from your device does not automatically result in consent withdrawal or any
deleting your personal data from our servers.
12. HOW WE TREAT CHILDREN’S DATA
12.1. We acknowledge the importance of protecting children’s data and confirm our
special duty to act accordingly. Despite we do not intentionally collect, store or
otherwise process any personal data of users under the age of 16, unless we are
furnished with the duly obtained consent for that from their parent, legal guardian or
other holder of parental responsibility.
12.2. If we learn that we have unintentionally collected personal data from a child
under 16 (or a child who has not reached the age of consent in accordance with their
applicable legislation) without the consent of that child’s holder of parental
responsibility, we will take all reasonable steps to erase this information as soon as
possible.
12.3. If you find out that your child has provided us with their personal data without
your consent, or you believe that we have unintentionally collected your child’s data
and processed such data in violation of applicable law, you the right to request the
your providing us with conclusive evidence that:
● the child has not yet reached the minimum age of consent in accordance with
their applicable legislation, and
● you are the holder of parental responsibility of such child.
12.4. We strongly encourage parents, legal guardians or other holders of parental
responsibility to instruct their children to never disclose their real names, addresses,
phone numbers or any other sensitive data about themselves when using our
services, in game chats, on the websites (forums, commentaries, etc.) and otherwise
on the Internet.
13. HOW WE PROCESS YOUR COOKIES
We may use cookies and other similar tracking technologies (such as web beacons,
pixels, device ID, etc.) to recognize you and/or your device for the purposes
described in this Privacy Policy. In order to find out more details about our use of
cookie files, please see our Cookies Policy available at: [email protected].
14. HOW WE UPDATE THIS PRIVACY POLICY
We may change this Privacy Policy at any time. In case of substantial changes,
updated policy shall be subject to a relevant update notice and refreshing your
consent. Unless you agree with the revised version of this document, we reserve the
right to suspend providing you our services which require your data processing by
us. In case of minor changes no notice follows, you undertake to check such
changes by yourself. Any updates to this Privacy Policy come into effect next day
from the at which the updated version of the Privacy Policy is published moment (last
revised and effective date).
15. HOW TO CONTACT US
15.1. If, after reviewing this Privacy Policy, you still have any questions on our
processing your data, please contact us at [email protected]
15.2. Please also consider that for security reasons your requests concerning
exercising your personal data rights as mentioned, among others, in Sections 6, 8,
11 and 12 shall be submitted through our support service at: [email protected]
