Privacy and Cookies Policy
Effective Date: 25th of May, 2018
1. Introduction and Applicability of This Policy
- organizing it into the sections listed in the Table of Contents below,
- providing a series of examples that help illustrate how the policies may be implemented by us and
- defining and capitalizing a few terms that are used more than once, for the sake of simplicity and brevity.
2. Data Controller Details
2.1. Throughout this document, “Company”, “Tanki X”, “we”, “us”, “our” and “ours” refer to
Tanki Online Europe Ltd. (“Data Controller”)
Address: 60/2, Melita Street, Valletta VLT 1122, Malta
Contact E-Mail: email@example.com
3. Table of Contents
- Introduction and Applicability of This Policy
- Data Controller Details
- Table of Contents
- Data We Collect and Receive
- How We Use Data
- Who We Share Your Data With
- International Data Transfers
- Data Retention
- Security Safeguards
- Age Limits
- How To Exercise Your Personal Data Rights
- Contact US
4. Data We Collect and Receive
4.1. In order to provide the Services, we may collect or receive data, which may include the information voluntarily provided in the course of filling special forms in the Game, the information provided during the registration process, subscription to the Services, publication of materials and request for other services or information collected automatically during the course of providing the Services.
4.2. Data You Provide Us With
4.2.1. Account Data
To register or update an Account, you may be asked to provide Personal Data including, but not limited to, your username, email address, phone number, password.
4.2.2. Communication and Content Data
When you communicate with us or submit a report about problems with the Services, post any content or messages, or provide any other information within the Services, we may process all of this information. This data includes:
- data that you post, comment or like in any of the Games’ Forums and Sites;
- data sent through the “game-chat” functionality in the Games;
- data you provide through our support channels;
- payment data, when you purchase a product or service from us, including information necessary to process your orders with the relevant payment provider, which may include the amount of any transaction, but will not include your financial information or cardholder data, which will only be submitted directly to the payment service provider under secure protocols; you can find further information in the current data protection guidelines of the respective payment providers;
- information other than the Account data you provide to us when participating in competitions, contests and tournaments, responding to surveys, e.g. your contact details;
- information regarding your profiles on social networking sites in order to allow integration with such social networking sites.
Please note that information that you voluntarily make public, or which you post publicly (for example in the game-chat or forum), will be publicly available and viewable by others. We do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions.
4.2.3. Other Data
We may request any information required to organize and conduct events in the Game when you register to participate in such events initiated by us.
4.3. Data We Collect Automatically
4.3.1. Usage Data
The browser or a client program may transfer certain information about the details of visits to the Services, including
- information about traffic, log-files, user activity information;
- IP-address and mobile device identifiers (such as your device ID, advertising ID, MAC address, Android ID, IMEI);
- general location data;
- social platform ID
- browser and device information, operating system;
- data about your use of the Services, such as gameplay data and your interactions with other players inside the Services and other information.
In most cases, when you use the Services, we also create for you an in-game identifier such as an Account ID.
4.3.2. Cookie files
Cookies stored on your computer or device through which you use the Services have amongst others but without limitation, the following functions:
Authentification. If you’re signed in to our Services, cookies help us show you the right information and personalize your experience.
Preferences and Features. Cookies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
We use the following first-party cookies on our Sites:
|ips4_hasJS||1 day||Preferences and Features|
|ips4_ipsTimezone||session||Preferences and Features|
|TXclientId||1 year||Analytics and Research|
|TXuid||1 year||Analytics and Research|
|TXvisit||1 year||Analytics and Research|
|TXclientId||1 year||Analytics and Research|
The first-party cookies are stored for no more than one year.
We may use the following third-party cookies:
Google Analytics (Analytics Cookies)
To Opt-out: Download the browser plugin “Google Analytics Opt-out Browser Add-on” here.
Google AdWords (Marketing Cookies)
To Opt-out: Visiting Google’s Ads Settings.
Yandex.Metrica (Analytics Cookies)
To Opt-out: Visiting Yandex Metrica opt-out add-on.
You can control and/or delete cookies as you wish by changing your browser settings. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.
5. How We Use Your Data
5.1. To Provide the Services to You
To provide the Services to you and to perform our contract with you, we use your information, which is necessary:
- to register and administer your Account, and to verify your details,
- to provide you with the Services you request;
- to verify and confirm 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 participation in competitions, rewarding you with gifts and awards to which you may be entitled as a result of winning an online or offline competition, etc.
5.2. To make the Service more suitable for our players
5.2.1. To provide a great Service to our players, we have a legitimate interest in collecting and processing the necessary data to
- Update and develop player profiles;
- Develop and improve the Service and player experience;
- Manage our relationship with you;
- Provide social features as part of the Service;
- Customize your Service experience;
- Respond to your comments and questions and provide player support;
- Notify you and provide you with information about features on our Sites, new product releases and service developments, and to advertise our products and services;
- Provide you with special offers inside the Service as well as in other websites and services, and by email;
- Send you related information, such as updates, security alerts, and support messages;
- Enable you to communicate with other players.
You may opt out of receiving promotional communications from us. To find out how to do this, please refer to section 11.7. “Request That We Stop Using Your Data”.
5.3. To Keep The Services Safe And Fair
5.3.1. In order to keep the Service and its social features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to
- Analyze and monitor the use of the Services;
- Take action against fraudulent, cheating or disruptive players.
5.3.2. If the data can be used to prove that cheating, fraudulent activity, or EULA violation has occurred, we will further store the data for the establishment, exercise, or defense of the legal claims for the duration of the applicable statute of limitations.
5.4. With Your Consent
5.4.1. With your consent, we may process your data for additional specific purposes.
5.4.2. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time (to find out what to do in this case, please refer to section 11.9.), but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean that you will no longer be eligible to use the Services.
6. Who We Share Your Data With
6.1. We share information we collect about you in the ways discussed below and only when necessary for the performance of a contract with you, compliance with a legal obligation to which we are subject, or based on our legitimate interests. We are not in the business of selling information about you to advertisers or other third parties.
6.1.1. Payment Services: we share your email address, IP address, information about your in-game purchases at the Services, and other information you provide to us with payment provider companies for the purpose of fulfilling your purchase requests.
6.1.2. Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Services.
6.1.3. Customer Support Services: we engage third-parties to help us provide customer support for some territories and products. Such companies may have access to your personal data, including personal data that you may provide in your customer support requests.
6.1.4. External Moderators and Testers: some limited data about you (such as your nickname, IP-address) may become available to third-party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Games.
6.1.5. Developers of the Game Software: for the purpose of developing and supporting the Game Software, we may share your nickname, e-mail, IP-address and some other information with third-party developer companies.
6.1.6. Advertising and Advertising Measurement Partners: we may 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, or otherwise facilitate the transmission of information that may be useful, relevant, or of interest to you.
6.1.8. Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you, for instance to show trends about use of the Services.
6.1.9. Publicly available information: our Sites may offer publicly available chats, forums, and blogs that are viewable by others. Please note that you post publicly available information at your own risk. We are not liable for any information that you voluntarily choose to be public through such and/or other explicit actions.You should be aware that any information you provide on these communication services —including your Account information— may be read, collected, and used by any member of the public who accesses these communication services. Your posts and certain Account information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as specified below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to, and why.
7. International Data Transfers
7.1. Our Service is global by nature and your data can, therefore, be transferred to anywhere in the world. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
7.1.2. International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to Russia and allow access to that information from countries in which our owned or operated companies have operations for the purposes described in this policy. These countries may not have privacy and data protection laws equivalent to the laws of many of the countries where our customers and users are based. When we share information about you within and among corporate affiliates, we make use of standard contractual data protection clauses that have been approved by the European Commission.
8. Data Retention
8.1. We retain your data for as long as your account is active, or as long as is needed to provide you with the Service. We will periodically de-identify unused game Accounts, and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
8.2. Content you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the Services. For example, we continue to display messages you posted on the forum, and continue to display content you provided.
8.3. Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created.
9. Security Safeguards
9.1. In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
10. Age Limits
10.1. We do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under the age of 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
11. How To Exercise Your Personal Data Rights
11.1. You have certain choices available to you when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.
11.2. You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the Contact Us section below to request assistance.
11.3. Your requests and choices may be limited in certain cases, such as when fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
11.4. Access Your Data (Right of Access): Upon your request, we will provide you with a copy of your personal data in a structured, electronic format.
11.5. Change or Correct Your Data (Right to Rectification): You can edit some of your personal data (such as your email address) through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
11.6. Delete Your Data (Right to Erasure): You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and game-related information linked to the Account, subscriptions to forums, and the possibility to access other services for which you are using the Account. Please note that once your Account has been deleted, you will lose your gaming experience and all Digital Content.
11.7. Request That We Stop Using Your Data (Right to Object): 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 is necessary for the establishment, exercise or defense of legal claims. You can also opt-out of our use of your information for marketing purposes by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
11.8. Data Portability: Data portability is the ability to obtain some of your personal data in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.
11.9. You may withdraw consent where processing of your personal data is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
11.10. We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will where possible, provide the relevant information electronically unless you request otherwise.
You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.
12. Contact Us
12.1. If you have any questions about how your personal data is collected, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at:
Tanki Online Europe Ltd.
Address: 60/2, Melita Street, Valletta VLT 1122, Malta
Contact E-Mail: firstname.lastname@example.org