Defipanzer
PRIVACY POLICY
Effective: 22 November 2021
We are committed to protecting and respecting your privacy. This
Privacy Policy (“Policy”) describes how we
collect, process, use and share your personal information when you download and
play our games and use our websites, applications and other products.
By “Personal Data”, we refer to data
that relates to you as an identified or identifiable natural person. The term
“Personal Data” may include, for example, your name, your postal address, your
telephone number, your e-mail address, your age, your gender, and your game
preferences. Anonymous or de-identified information, which we are not able to
identify you, does not qualify as “Personal Data”.
1. CONTROLLER’S NAME AND CONTACT
DETAILS
The data controller in respect of our Products (as defined
below) is:
DefiPanzer Group Limited
Islamabad
Email: admin@defipanzer.com
In this Policy, “DefiPanzer”, “we”, “us” or “our” means DefiPanzer Group Limited and the term “Products” means:
(i) Mobile games that post a link to this Policy and are made
available through the Sites, the DefiPanzer Game Center and game platforms such
as iOS and Android (the “Games”)
(ii) Our websites that post a link to this Policy, including
those at:
(“Site”)
(iii) Our products and
applications (including support applications and forums) related to the Games,
including “Defi Panzer Assistant”, “DefiPanzer Check” and “DefiPanzer Game
Center”; and
(iv) DefiPanzer account (“Account“) and any other
online game, website, application and product operated by us that posts a link
to this Policy.
This Policy also applies to any of our offline activities that
make this Policy available to you.
2. CONTACT DETAILS OF THE DATA
PROTECTION OFFICER (DPO)
For questions regarding this Policy, our data practices, or our
compliance with applicable laws, please contact our Data Protection Officer as
follows:
DefiPanzer Data Protection Officer
Islamabad
Email: admin@defipanzer.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 your interests or fundamental rights and freedoms for which
require the protection of your Personal Data.
Our legitimate interests are to render and improve our Products
in an effective, safe and harmless manner. We want to provide everyone with a
fair and balanced experience when using our Products.
4.1. YOUR PREFERENCES
You can choose how we use your Personal Data using the Account
Management tool. As we need to verify your identity before we follow your
instructions on Personal Data use, you need to have a registered Account in
order to access the Account Management tool. This means that if you are using a
demo version of the Account, you will only be able to fully control our use of
your data after you complete the Account.
For example, through the Account Management tool you can:
·
opt-out of receiving direct marketing, offered via email, within
Games and online. Read more below in Section 8.1 “Opt-Out of Direct Marketing
and Right to Object”;
·
access the Personal Data we collect and store about you. Read
more below in Section 8.2 “Right of Access”;
·
have your Account, and the related Personal Data, deleted. Read
more below in Section 8.4 “Right to erasure”.
4.2. INFORMATION SECURITY
We maintain reasonable and appropriate security safeguards
designed to protect your information from loss, theft, misuse and unauthorized
access, disclosure, alteration and destruction, taking into due account the
risks involved in the processing and the nature of the information.
4.3. 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 Products. 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 unless so
instructed by us.
4.4. CHILDREN
We recognise that we have a special obligation to protect
personal information obtained from children. We do not knowingly collect
Personal Data from any child, or process such information, without parental
consent. For the purpose of this Policy, a child means any individual who is
under the age of 18 (or the minimum legal age to consent to the collection and
processing of Personal Data where this is different under applicable law). If
you are a parent or guardian and believe we have collected your child’s
information in violation of applicable law, contact us at admin@defipanzer.com. We will remove the information in
accordance with applicable law.
4.5. DATA RETENTION
We keep most of your Personal Data collected and processed for
the purposes described in this Policy for as long as you continue to use our
Products, e.g. you have an active Account in one of our Games. We will delete
your Personal Data after you request your Account to be deleted via the Account
Management and the grace period of 45 (forty-five) calendar days, during which
we can restore your Account, expires. The process of erasing your Personal Data
can take up to one month from expiry of the grace period and, considering the
complexity and number of requests, may be extended by a further two months.
Read more in Section 8.4 “Right to erasure”.
4.6. GAMES NOT USING THE ACCOUNT
Some of the Games do not use the Account. You will not be able to exercise your
rights with regard to those Games through the Account Management tool. For this
reason, we are offering you other tools to export your Personal Data, delete
them, and object to our use of your Personal Data in accordance with Section 8
“Your rights”, as well as to manage your subscriptions.
Also, there are some differences in the Personal Data that we collect about
users of the Games for which the Account is created and users of other Games.
With regard to the Games that do not use the Account, you can exercise your
rights by contacting directly our Player Support or as otherwise indicated in
the respective Game.
Where such function is available, you may link to your Account some of the
Games that do not use the Account. Please note that control over your Personal
Data in such Games is separate from control over your Personal Data relating to
your Account. For example, to delete your Personal Data in “Defi Panzer” you
will need to contact Player Support as suggested in this Game, while deletion
of the Personal Data relating to your Account shall be performed through the
Account Management tool.
5. INFORMATION WE COLLECT
In relation to your use of our Products, we collect information
either directly from you (when you provide information to us) or indirectly
(e.g. through our Products technologies).
5.1. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you provide
to us.
Account Data
When setting up an Account, you may be asked to provide Personal
Data including, but not limited to, your in-game name, in-game password and
email address. Once you set up your Account, you have the opportunity via the
Account Management settings to specify your date of birth for receiving gifts
at your birthday as well as to link your Account with your telephone number as
a second authentication factor tool or to receive marketing communication via
SMS. You can also use your credentials from other services such as Google,
Facebook or Twitch to create an account faster with us. In such case we may
collect additional information as per section 5.3 below. We also generate a unique
number / identifier which we call “DefiPanzer ID” in connection with your
Account and your use of our Products can be identified via DefiPanzer ID.
Content Data
We may obtain your Personal Data when you register for and use
our other Products, e.g. game forums, chats, or when you provide feedback about
our Products. These data include:
·
Information that you post, comment, share content or like in any
of the Games-related forums owned or operated by DefiPanzer (“Forums”), on the
pages of social network groups operated by DefiPanzer, and on the Sites;
·
Information sent through the “game-chat” functionality in the
Games, including through in-Game voice chat;
·
Information you provide when you request information or support
from us or purchase a product or service from us, including information
necessary to process your orders with the relevant payment merchant, which may
include the amount of any transaction, but will not include your financial
information, which will only be submitted directly to the payment merchant
under secure protocols;
·
Information other than the Account Data you provide to us when
participating in competitions, contests, tournaments, loyalty programs, at
offline events, responding to surveys, e.g. your contact details;
·
Information that you provide to us to become or as a participant
of alpha-tests, super tests, and UX tests.
Personal Contacts Data
To fulfill a request by you, we collect data about your personal
contacts, such as their name, nickname, email address, and phone number with
your consent, such as finding your contacts on our Products or inviting your
contacts to join our Products via our referral programs etc. By using such
functionalities, you acknowledge and agree that you have your contact’s consent
for us to use their contact information to fulfill your request.
Other data provided by you
voluntarily
You may choose to voluntarily provide other information to us
that we do not request, and, in such instances, you are solely responsible for
such information.
5.2. INFORMATION WE COLLECT
INDIRECTLY
We indirectly collect a variety of information through your
interaction with and use of our Games, Sites and other Products.
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.
5.2.1. 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 Products, and similar technologies (e.g. web
beacons, pixels, tags and device identifiers) to recognize you and/or your
device(s) on, off and across different devices and our Products, as well as to
improve the Products we are offering, to improve marketing, analytics or
website functionality. The use of cookies is standard on the internet. 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 any of our Sites, our servers log your computer’s IP address.
For more information about the names of the cookies used on our
Sites, the cookie provider (DefiPanzer, third-party analytics partner, or
third-party advertising partner), the purpose of the cookie (necessary for
website to function, performance, or marketing), and the cookie life cycle, you
may click on the Cookie Settings link found at the footer of each Site. This
link allows you to set your cookie preferences and control your cookie settings
at any time.
5.2.1.1. 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 choice 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. for
Chrome https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en), and by visiting
the following sites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.
Do Not Track: Your browser settings
may allow you to automatically transmit a “Do Not Track” signal to online
services you visit. Note, however, there is no industry consensus as to what
site and app operators should do with regard to these signals. Accordingly,
unless and until the law is interpreted to require us to do so, we do not
monitor or take action with respect to “Do Not Track” signals. For more
information on “Do Not Track” visit http://www.allaboutdnt.com.
5.2.2. Game-Related Information
In order to provide you with efficient services, we need to
collect, store and use various information about your use of our Games. “Game-Related Information” are stored under your DefiPanzer ID
as provided in the Account Data in section 5.1 above as well as what is usually
referred to as “game statistics”. By “game statistics” we mean information
about your Games preferences, progress in the Games, participation, performance
and achievements in clans and battles, frequency of playing, etc.
5.2.3. Device Information and
Geo-Location
In order to fix crashes and other technical issues that may
arise while you are installing the Games and using our Products, as well as to
make our Products more suitable for you, we collect, store and use information
about the device you are using the Products on, including what type of device
it is, what hardware and operating system you are using, the device settings,
unique device identifiers, and crash data (if any). Whether we collect some or
all of this information often depends on what type of device you are using and
its settings. You may also install applications collecting and using additional
data required for fixing crashes, errors and other technical issues arising
during your use of the Products, e.g., DefiPanzer Game Center and DefiPanzer
Check.
To make our Products more suitable for you and only upon your
permission we can also collect your precise GPS location from mobile devices.
Wi-Fi and IP addresses received from your browser or device may be used to
determine approximate location.
5.2.4. Information required for fraud
and violations detection
We may also collect certain data (like IP address, username,
etc.) that is required for our detection, investigation and prevention of
cheating in the Game and EULA violations. This data, being used only for the
purposes of detection, investigation and prevention of frauds and cheating in
the Game are deleted six months after their collection, unless the data can be
used to prove that cheating has occurred. If the data can be used to prove that
cheating or another fraud or violation has occurred, we will further store the
data for the establishment, exercise or defense of legal claims during the
applicable statute of limitations. Please note that the specific data stored
for this purpose may not be disclosed to you or any third parties, since the
disclosure will compromise the mechanism through which we detect, investigate
and prevent frauds and cheating in the Game, as well as other violations.
5.2.5. Information from publicly
available online resources
We may use the information made publicly available, e.g. through
YouTube, Facebook, Instagram and Twitter, in order to find out your opinion
about Games and Products, so that we could take them into account while
improving our Products. Such data collection can be carried out by DefiPanzer
independently, or received from our partners making analysis of public
sentiments on various issues.
5.2.6. Information from our partners
In some cases, DefiPanzer receives your personal data as a data
processor, which means that the data are controlled by our partners and we use
them only in accordance with their instructions and applicable laws. We use
this data in order to fulfill our obligation, improve the Products, and when
processing is required in order to comply with a legal obligation to which we
are subject.
Payment partners. When you
purchase in-game items, in-game currency, or time-limited premium memberships
with your credit card, we may receive from our payment partners and process a
part of your credit card number, information about your credit card issuer, as
well as your full address for billing purposes;
Co-Promotion Partners. In order to
provide you with in-game items and/or in-game currency for participation in
various loyalty programs, we may also receive information from our partners,
such as telecommunication companies, banks, cash back partners, travel
agencies, and others;
Platforms. We also receive and
use your identifiers and other information on other platforms like App Store,
Google Play Store, Steam, so that you can play our Games through these
platforms;
Social networks. We have
registered certain Games-related group accounts and pages at Facebook, YouTube,
Instagram, Discord, Twitter, Reddit, and other social networks to better
communicate with our players in case they have questions about our Products, as
well as prefer to learn about news about our Products through the social
networks. Also, we get information relating to your account on social
networking sites in order to allow you to integrate or link your social network
account with your Account or our Products. For example, you may link your
Account via your YouTube account credentials. In such case, we will collect
from YouTube your channel ID to link your social network account with your
Account. If you are a content creator, we may access your channel
subscribers/members to find our players’ accounts to provide them with some
in-game customization or goods. Any personal data collected from such sources
will be stored in accordance with this policy.
We also automatically collect information via our Games
application technologies that are not browser-based like cookies and cannot be
controlled by browser settings or cannot be controlled via the Account
Management tool or while you play our Games. For example, our Games
applications may include SDKs, which is code that sends information about your
use to a server, for instance through the Facebook SDK or other partner’s SDKs.
These SDKs allows us to track our conversions, bring you advertising, and
provide you with additional functionality, such as the ability to connect our
Products with other services.
5.3. INFORMATION FROM OTHER SOURCES
The categories of sources from which we collect information
include:
5.3.1. Game platforms: We collect
data (such as the relevant user identifier, email, nickname), from partners
that make our Games available on their platforms, such as Valve (Steam), Apple
(iOS), and Google (Android). Our partners, and not us, are responsible for your
accounts on their platforms, and we recommend that you review their privacy
policies. When you play our Console Games, we collect data (such as email) from
the gaming platforms on which you play the Console Games. Such gaming platforms
are responsible for your accounts on their platforms, and we recommend you
review their privacy policies.
5.3.2. Developers who use our API: We collect
data from developers who use the DefiPanzer API. Use of API is subject to our
API Terms of Use .
5.3.3. Verification partners: We collect
data from verification services such as ID me to confirm your eligibility for
discounts (e.g., related to your military status).
6. HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to perform the
contract with you. As a user, we will use your Personal Data, unless otherwise
prohibited by law, for the following purposes:
·
to provide you with the Products you request, i.e., to ;allow
your installation of the Games, operate the Products and verify and confirm
your payments;
·
to communicate with you about your Account or transactions with
us and send you information about features on our Sites or changes to our policies;
·
to provide support including, but not limited to, product
updates, product patches and fixes and other similar communications;
·
to arrange your travel, receipt of gifts and awards, to which
you may be entitled as a result of winning an offline competition, etc.
6.1. COMMUNICATION PURPOSES
We will use your Personal Data for our legitimate interests to
advertise our Products in accordance with this Policy. Namely, once you have
created an Account we may use your email address, nickname, IP address, mobile
phone number, in order to send you personalized marketing emails, messages,
targeted in-game and web offers about Games. Also, if you opt-in, we will send
you personalized marketing emails, messages and in-game and web offers about DefiPanzer
offline events, co-projects of DefiPanzer and its partners, as well as about DefiPanzer
games, not using DefiPanzer ID.
6.2. PRODUCTS IMPROVEMENT PURPOSES
We analyze your information to identify how to improve the
Products and our operations to make them more suitable and interesting for our
players in general. We also may ask you to respond to our Products-related
surveys or questionnaires, and you always have the choice about whether to
respond to them and which information you provide.
6.3. FRAUD AND VIOLATIONS DETECTION
We use the information required for our detection, investigation
and prevention of cheating in the Game and violations and Game Rules and
policies only for the purposes of detection, investigation and prevention. If
the data can be used to prove that cheating or another fraud or violation has
occurred, we will further store the data for the establishment, exercise or defense
of legal claims during the applicable statute of limitations.
6.4. AUDIENCE MATCHING SERVICES
We will also use your information for audience matching services
to reach people (or people similar to people) who have used or visited our
Products or are identified in one or more of our databases. This is done by us
sharing a list of hashed emails. For instance, we use Facebook Custom Audiences
to serve ads to our players on Facebook and Facebook Lookalike Audiences to
serve ads to users on Facebook similar to our players.
Vendors and ad partners may act as our processors or in certain
contexts, they may act as data controllers and independently decide how to
process your information. We encourage you to familiarize yourself with and
consult their privacy policies and terms of use. To opt-out of us sharing your
hashed email address for please contact us at admin@defipanzer.com and specify that you wish to
opt out of. We will remove your email address from any subsequent lists shared
with ad partners for purposes.
7. 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.
Payment partners: we share your
email address, IP address, information about in-game purchases requested by you
at DefiPanzer’s web-site, and other information you provide to us for the
purpose of fulfilling your purchase and withdrawal requests;
2.
Advertising and advertising measurement
partners: we share your email, nickname, IP address and other
information you provide to us in order to facilitate targeting, delivery, and
measurement of online advertising on third-party services, facilitate
transmittal of information that may be useful, relevant, or of interest to you,
e.g.. allowing you to get rewards for viewing in-Games advertisements. These
parties may act as our processors, or in certain contexts, independently decide
how to process your information;
3.
Data storage partners: we store some
of your information using third-party data storage services owned or operated
by other entities.
4.
Software providers: proper
Products rendering requires us to use software solutions of third parties,
e.g., for our in-Games questionnaires, including storage of your replies,
5.
Research partners: we may
provide access to some of your data, such as your Game statistics, to provide
marketing-related and other research. We share anonymous data with our partners
unless your personal data is necessary for the requested services or research;
6.
Player Support partners: for some
territories and products we engage third parties to provide you with
appropriate player support services. Such companies may get access to your
personal data, including personal data that you may provide in your player
support requests.;
7.
Developers of applications based on
the Game: we make your nickname and some of your Game statistics
available to other players and our partners through Public API. The data can be
used for developing and support of the applications created by the Game
community, mobile applications, e.g. DefiPanzer Assistant, authorized modes to
the Games. Public API enables us to improve your gaming experience, fulfill
potential of our games’ community, and put use of our players’ statistics under
our control by creating rules and requirements for their use by other players
and community. Use of your information is subject to the restrictions set out
in our API Terms of Use;
8.
Information available to other
players: making your nickname and game statistics available to
other players through our Products is an important part of making players’
experience more enjoyable. If you are banned in a Game based on other players’
complaints, we may inform them about the ban. Please note that members of your
clan have access to a bigger amount of your game statistics than others;
9.
Public information: our Products
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 and
you are solely responsible for any information you make public. Your nickname
and game statistics may also become available within Games replays and other
videos, which DefiPanzer or other players may generate and put online. Please
do not include into your nickname any data that can identify you personally. To
change your nickname please contact Player Support;
10. External moderators and testers: some
information about you (such as your IP address, nickname, content of Player
Support ticket) may become available to volunteering moderators and testers who
contribute to providing you with better Products, e.g. to quickly respond to
your questions about the Games. We ensure that use of your information by
moderators and testers in this context is subject to confidentiality and data
protection agreement.
11. Anti-cheat and anti-fraud companies: we may share
the information required for our detection, investigation and prevention of
cheating in the Games and only for the purposes of detection, investigation and
prevention of cheating in the Game.
12. Logistics partners: to arrange your trips and
deliver the prizes you may be entitled to thanks to use of your Products, we
can share your post address and other required details with our logistics
partners or ask you to share that data with our logistics partners directly;
13. Third-party websites: you can choose to log into some
websites using DefiPanzer Open ID. In this case we pass to the websites your
nickname and your profile link. Please check our Player Support articles on
Open ID for more details and note that DefiPanzer does not control further use
of this data by third-party websites, i.e., we cannot request their erasure of
your data;
14. Game Developers and Change of Publisher: DefiPanzer is the
data controller with regard to certain Games developed by third parties and
published by DefiPanzer. Such developers can process certain data required for
the Games’ and other Products’ further improvement, e.g., to Game-Related
Information. Should DefiPanzer transfer the right to publish such or other
Games and other related Products to a third party, the new publisher will have
the right to continue using your data in the manner substantially the same as
set out in this Privacy Policy unless you are specifically informed otherwise.
15. 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 the laws
of each local jurisdiction where we operate;
16. DefiPanzer subsidiaries and affiliates: as a global
company, we share information with our affiliates and related entities which
they act as our processors. This information may be processed in our offices
worldwide. Your information may also be processed outside of the jurisdiction
in which it was collected.
17. Change of control: we may share your information
as part of, or during the negotiation/preparation of, our company’s sale,
merger, change in control, or any other type of acquisition or business
combination of all or any portion of our assets, or transfer of all or a
portion of our business to another business. In addition, should we transfer
the right to publish any Games or other related Products to another entity, the
new publisher will have the right to continue using your information in the
manner substantially the same as set out in this Policy unless you specifically
informed otherwise.
18. Third-party game developers: We also publish on our platform
(DefiPanzer Game Center) games developed solely by third party developers. When
you choose to play such games, we may share your data with the third-party game
developer, such as your DefiPanzer ID, nickname, in-game purchases, in-game
bans of our Games, language preference of DefiPanzer Game Center. In such case
we and the third-party game developer act as independent data controllers. Such
third-parties are responsible for your activities on their platforms and we
recommend you review their privacy policies.
19. Security and compelled disclosure: We share
information to comply with the law or other legal process (e.g., tax and
customs authorities, auditors, and where required, in response to lawful
requests by public authorities, including to meet security or law enforcement
requirements). We also share information to protect the rights, property, life
health, security and safety of us, the Products, or anyone else;
20. Competitions: Our competitions, contests, and tournaments (“Competitions“) may be jointly sponsored or offered by other parties.
When you voluntarily enter a Competition, we share information as set out in
the official rules that govern the Competition as well as for administrative
purposes and as required by law (e.g., on a winners list). By entering a
Competition, and may, except where prohibited by applicable law, allow the
sponsor and/or other entities to use your name, voice and/or likeness in
advertising or marketing materials.
When your personal data is shared with DefiPanzer affiliates and
subsidiaries, as well as third parties outsider, The DefiPanzer guarantees an
adequate level of personal data protection, including but not limited to, by
entering into standard data protection clauses adopted by the Outsider
Commission with DefiPanzer 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.
Sharing anonymous information. We also may
share anonymous information, i.e. information which does not directly or
indirectly disclose your identity, and aggregated information (meaning
information about groups and categories of users, including game statistics and
behavior, but which does not identify and that cannot reasonably be used to
identify any individual user) with our advertising partners. We may also allow
our advertisers to collect anonymous information and aggregated information
within the Products and they may then share that information with us. Our
advertisers may collect this information through the use of tracking
technologies like cookies and web beacons. This enables our advertisers to
develop and deliver targeted advertising in the Products and on the websites of
third parties, so that they can try to serve you with advertisements for
products and services that are most likely to be of interest to you.
Advertisers will also use this information to monitor, improve or modify their
operations.
8. YOUR RIGHTS
To allow you to exercise your data protection rights in a simple
way we have improved the Account Management tools available here and – for Console Games – here. If you are using a demo account, you will only be able to
fully control our use of your data after you create the Account here or – for Console Games – here. This means that if you are using a demo version of the
Account, you will only be able to fully control our use of your data after you
complete the Account here. Please visit it to make choices about which direct
communications you would like to receive, as well as to exercise your rights to
data access, data erasure and objection to data processing. In some cases, for
games developed solely by third parties and published by DefiPanzer on DefiPanzer
Game Center (see section 7(18) above), you can exercise your rights directly
from the third-party developer. You may contact us to assist you on how you can
exercise your rights for games developed solely by third parties.
If you have linked your Account with linked services (e.g.,
Google, Microsoft, Facebook, Steam, Twitch etc) you may unlink your accounts at
any time through the Account Management settings. Please note that unlinking
your accounts will not affect any information previously shared through
linking. We are not responsible for the data practices of any other parties,
and we recommend that you carefully review their privacy policies and terms of
use.
8.1. OPT-OUT OF DIRECT MARKETING AND
RIGHT TO OBJECT
You can manage your subscriptions to direct marketing through
our Account Management tool. Please note that even if you unsubscribe from all
our personalized marketing emails, messages, in-game and web- offers, we will
still send you some notifications (we often refer to them as “transactional”),
e.g. to confirm purchases or changes in your Account, give warranty or security
information, information about changes to the, Terms of Service and Privacy
Policy, as well as will show to you non-personalized marketing in-game and web
offers. We will be able to stop all communications only after your Account is
deleted. Also, even after you have unsubscribed from our in-game and web
offers, you may still see them within the Games and on some web-sites: that
would mean that such offers are shown to everyone or to a very broad audience
and are not specifically directed to you.
You can opt-out of personalized advertising in mobile
applications, including our mobile Games, by checking the privacy settings of
your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or
“opt-out of interest-based ads” (Android). You can adjust your mobile push
notifications in your Android or iOS device settings menu.
Where processing of your Personal Data is based on legitimate
interests, you can use your right to object at any time. If you object we will
no longer process your Personal Data unless there are compelling and prevailing
legitimate grounds for the processing or the data are necessary for the
establishment, exercise or defense of legal claims.
8.2. 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. You can use the right to access to your Personal Data
through the “Data Export” tool available in the Account Management tools here and – for Console Games – here. 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 Products regardless of our request not to
provide the Personal Data in this particular field, website, etc.
8.3. RIGHT TO RECTIFICATION
You control which nickname, email, phone number, country (only
in exceptional circumstances), social networks accounts, trusted sites and
payment methods we associate with your Account. If they change, please modify
the data in the Personal Account directly. Please inform us if any of the
Personal Data we retain about you is inaccurate.
8.4. RIGHT TO ERASURE
You have the right to obtain deletion by us of Personal Data
concerning you by deleting your Account via our “Account Deletion” tool
available in the Account Management tools here and – for Console Games – here.
As a result of deleting your Account, you will lose access to
most Products, including the Account and Game-Related Information linked to the
Account, subscriptions to DefiPanzer forums and the possibility to access other
services you are using the Account for.
Grace period. We allow you
to restore your Account during a grace period of 45 (forty-five) days from the
moment you request deletion of your Account. This functionality allows you not
to lose various Game-Related Information and other important information and
options by mistake. During the suspension period, we will be able to finalize
financial and other activities that you may have initiated before sending the
Account deletion request.
No payments after Account deletion. As a result
of deleting your Account, you will lose the possibility to make payments in the
Premium Shop, including during the grace period. Should any payment be made
after Account deletion due to a technical error or for any other reason, we
will refund the amount paid by you and will not grant you the rights to the
respective Additional Features.
Complicated Account deletion. In some
cases, deletion of your Account, and therefore Personal Data deletion, is
complicated. Namely, if you are a clan commander in the Games, it is highly
likely that you will only be able to delete your Account after you have
transferred the clan and placed it under the command of another user or
dissolve the clan. In some 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.
Earlier Personal Data deletion. We store most
Personal Data we retain about you until you request deletion of your Account
through the Account Management tools. However, certain Personal Data is deleted
even while you have a valid Account. For example, we will delete:
·
your Contact Data, clothes sizes, color preferences, etc., you
have provided for customization, or for us to send you an award or arrange
travel to one of our events, within 45 (forty-five) days after us sending the
award to your address;
·
the data about you that we have collected in the course of
alpha-tests, super tests, UX tests, surveys, analysis of publicly available
sentiments in social networks such as YouTube, Facebook, Instagram, at onsite
events: within no longer than 45 (forty-five) days after completion of the data
analysis, data aggregation and generating of the reports for our Products
improvement;
·
technical logs such as records of communication between
Products, access logs, errors logs: normally within 45 (forty-five) days after
their creation.
Information we retain. Upon expiry
of the suspension period we will delete all your Personal Data, except for the
data which are required for our compliance with the requirements of applicable
laws (e.g. tax and accounting requirements) or for our detection, investigation
and prevention of cheating in the Game and violations or to resolve disputes
and enforce our agreements. We will also retain anonymous or de-identified
information after your Account has been deleted. Information you have shared
with others (e.g. through in-Games chats, updates or group posts) will remain
visible after you have deleted your account or deleted the information from
your own profile or mailbox, and we do not control the data that other
members/users copied out of our Products. Groups content associated with
deleted accounts will show an unknown user as the source. Your profile may
continue to be displayed in the services of others (e.g. search engine results)
until they refresh their cache.
COMPLAINTS
If you have any issues with our compliance you may contact our
Data Protection Officer as set out in section 2 above. You also have the right
to lodge a complaint with the data protection regulator in your jurisdiction.
10. 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. If the changes are
material, we may provide you additional notice to your email address.
ADDITIONAL DISCLOSURES FOR CALIFORNIA
AND NEVADA RESIDENTS
These additional disclosures apply only to California and Nevada
residents. For questions regarding this Policy, our data practices, or our
compliance with applicable laws, please contact us as follows:
United States
Address: Islamabad
Email: admin@defipanzer.com
This Policy has been designed to be accessible to people with
disabilities. If you experience any difficulties accessing the information
here, please contact us at admin@defipanzer.com
