Last Update: February 7, 2022
Table of Contexts:
- Who is the Data Controller
- Age Restriction
- Information We Collect and How
- Purpose of Processing Personal Data
- Legal Basis for Processing Personal Data
- Retention Period
- The Security of Your Personal Data
- Information We Share - Data Transfer
- Your Rights
- Do not track signals
- Contact Us
- National Data Protection Authority in Cyprus
- Links to other Websites
a. our website totalbattle.com (hereinafter the “Site”);
b. our mobile application of the Game (hereinafter the “Mobile Application”);
c. our downloadable clients of the game: Desktop client and Steam™ client (hereinafter the “Game client”);
d. our game in Facebook™ App center (hereinafter the “Facebook™ App”);
and any other Services related to the game offered by SCOREWARRIOR LIMITED (HE348535 Republic of Cyprus) established at: 16 Spyrou Kyprianou Avenue, Divine Clock Tower, 1st floor, 3070 Limassol, Cyprus (hereinafter the “Company” and/ or “we” “our”, “us”) and regulates how we collect, use, process and treat your personal information when searching information about the game or registering, creating an account and playing the game.
1.3 An overall principle is that we do not collect more information than is reasonably necessary to provide you with the best user experience.
For the purposes of this Policy:
a. “personal data” means data that relates to you as an identified or identifiable natural person.
b. “data subject” (or User) is any living individual who is using our Service and is the subject of Personal Data.
c. “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
d. “data controller” means the natural or legal person, public authority, agency or other body which determines the purposes and means of the processing of personal data;
e. “data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
f. “usage data” is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
g. “cookies” are small pieces of data stored on your device (computer or mobile device).
h. GDPR is the EU General Data Protection Regulation 2016/679.
3. WHO IS THE DATA CONTROLLER
4. AGE RESTRICTION
We do not knowingly collect personal information about persons under the age of 16 in cases where we can control it. For example, it is not possible to control information that is communicated to us online. In any event, if we find that we have collected any personal information from a person under the age of 16 (in accordance with Article 8 of the Regulation), we will delete the information from our records immediately and we will terminate the account (if any). If you believe we may have collected information from a person under the age of 16, please contact us.
5. INFORMATION WE COLLECT AND HOW
5.1 We collect information about you directly from you, automatically through your use of our Service and from third parties. We may combine the information that we collect about you from these various sources.
5.2 Information you give us directly / Personal Data: When you are using the Game or by corresponding with us by email or otherwise, you may give us information about you. This includes but not limited to information you provide when you register to use the Game, subscribe to our Service, or when you report a problem with our Game. The information you give us may include:
a. Your email address;
b. Your first and last names and/or username and user ID;
c. Your date of birth;
d. Your gender;
e. Your location and time-zone;
f. Your address;
g. Desired payment method, amounts, payment terms, name and surname, place, telephone, e-mail during payment, full credit card details/ IBAN, data of depositor if defers from the payee;
h. Interface display language;
i. You in-game chat messages and history;
j. History of all your actions in the Game and or any blocking;
k. History of your purchase of Virtual Goods;
l. Your messages sent to our Support and history of all inquiries;
n. We may also collect certain data (like IP address, username, time of entry and re-entries etc.) that is required for our detection, investigation and prevention of cheating in the Game and EULA violations. These data are used for the purposes of detection, investigation and prevention of frauds and cheating in the Game. If the data can be used to prove that cheating or another fraud or EULA 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 EULA violations. In such cases we might also need to pass your information to fraud prevention agencies, or any other related organizations involved in crime and fraud prevention, such as the police.
o. We might use your data for the purposes of, in case you are living in EU, including it in the VAT invoices where we are legally required to do so.
5.3 Information we collect about you automatically through your use of the service/ Usage Data: We collect information that comes from you while you are playing our games, interacting with the application / website and other Services. Such information includes but not limited to what device and browser you are using, the way you play the game and your levels, profile visits, demographic information, geographic and geo-location information, statistical or aggregated information which does not directly identify a person, but it may be derived from personal data, and the information that you provide us with directly. Additionally, information we collect via cookies. For more information, please refer to the proper section of this policy and to our Cookies Banner/Policy.
5.4 Information we receive from other sources: If you use any of the other platforms that we provide our services, we may receive information (such as the relevant identifier, email, nickname) about you from these platforms/our partners. Furthermore, we may receive information about you from our partners, with whom we are working closely, including but not limited to Facebook, Google (Android), Apple (iOS), business partners, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies. Our partners, and not us, are responsible for your account on their platforms, and we recommend that you review their privacy policies.
a. Information from publicly available online sources. We may use the information made publicly available, e.g. through YouTube, Facebook, community pages in order to find out your opinion about our Games and Services and improve our Services. Such data collection can be carried out by our Company independently, or received from our partners.
b. Information from our partners/third parties. In some instances, our partners are the personal data controllers, and we receive your personal data as the data processors meaning that we use them in accordance with their policies, instructions, and applicable laws. We will use this data in accordance with the entire legal framework and especially the EU 679/2016 Regulation (General Data Protection Regulation).
c. Payment Service Providers. When conducting online purchases in the Game, our Payment Service Providers, perform the processing of your payment. In such instances, the information you may give to our Payment Service Providers may include the desired payment method, amounts, payment terms, name and surname, place, telephone, e-mail during payment, full credit card details/ IBAN or data of depositor if defers from the payee. We may receive from our Payment Service Providers and process a part of this information, including but not limited to name and surname, a part of your credit card number, information about your credit card issuer, email address.
d. Platforms. We may also receive and use information on other platforms like Facebook, App Store, Google Play Store, so that you can play our Game through these platforms.
e. Social Network/media or Game content on other websites. We have registered Game - related group accounts and pages at social networks like Facebook™. Users can communicate with us through these accounts and pages for any questions and/or suggestions and/or updates. In case you create an account through our game in Facebook™ App center, we may get and/or receive information relating to your Facebook™ account. All personal data collected from these sources will be processed and stored in accordance with the General Data Protection Regulation.
6. PURPOSE OF PROCESSING PERSONAL DATA
a. To respond to your submissions, questions, comments, requests and complaints and provide customer support;
b. To monitor and analyze usage of the Game and trends in order to personalize and improve the Game and experience of our users while using any of the Sites, Game or Services;
c. To provide relevant content, ads in -game offers and features that matches your or other people preferences;
d. To increase functionality and general quality of the Game;
e. To send you confirmations, updates, security alerts and support/administrative messages;
f. For marketing campaigns purposes, including (without limitation) email marketing campaigns;
g. To provide competitions;
h. To prevent cheating, fraud and crime and to verify your compliance with our terms and conditions and our policies;
i. To meet legal and tax obligations and to carry out financial, regulatory and management reporting, and audit and record keeping;
j. To provide and maintain our Service;
k. To notify you about changes to our Service;
l. To allow you to participate on interactive features of our Services when you choose to do so;
m. To gather analysis or valuable information so that we can improve our Service;
n. To detect, prevent and address technical issues;
o. For any other purposes, which we believe are necessary and for which the information is collected;
p. to protect our property rights and to enforce our legal rights.
7. LEGAL BASIS FOR PROCESSING PERSONAL DATA
According to Article 6.1 of the GDPR, we rely on the following legal bases for the collection and use of your personal information:
a. You have given your consent to the processing of your personal data for one or more specific reasons. We may sometimes ask your consent to collect other information from you or your device. In such instances, we will inform you about the information we would like to collect, the reason we need it and what we will use it for. You have the right to withdraw consent at any time.
b. Processing is necessary in order to enter into or perform a contract with you. For example, we may need to use your information in order to provide you with the information, products and services that you request from us or information about goods and services we feel may interest you, to notify you of changes to our Service etc.
c. Processing is necessary for compliance with legal obligations we are subject to. For example, to prevent fraud or potentially illegal activities and, to take action against fraudulent or misbehaving players, or to keep our Service and its features safe, we may use your data.
d. Processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests, rights or freedoms, such as for the purposes of data analysis, testing, research and surveying, as well as for the purposes of marketing and promotion of our products.
8. RETENTION PERIOD
We store personal data for as long as required by the respective processing purpose and any other lawful linked purpose.
Personal data that are collected under the legal basis of ‘Legal Obligations’, are maintained after the expiry of the legal obligations as long as the relevant institutional framework permits.
Data that may be necessary for our legitimate interests as the controller are kept until the reason for such storage has expired.
Personal data of expression of interest through a query or a complaint are kept no longer than 6 months after the query or the complaint is answered and permanently settled.
Players’ personal data are kept for 5 years since the last day of active participation in the game. We will delete your Personal Data after you request your Account deletion and within one month of the request receipt rendering impossible the reactivation of your deleted account.
Cookies are kept for no longer than two years.
Specifically for personal data we process based on your consent (e.g. for marketing purposes), such data is kept from obtaining your consent and until it is revoked.
Personal data that are no longer necessary are safely destroyed or anonymized.
9. THE SECURITY OF YOUR PERSONAL DATA
We have implemented reasonable and appropriate organisational and technical measures to protect the personal data and the entire information we collect from security risks.
10. INFORMATION WE SHARE - DATA TRANSFER
For the performance of a contract with you, compliance with a legal obligation we are subject to, and based on our legitimate interests, we may share or disclose your personal data with the following categories of third parties:
a. business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
b. third party companies that perform services on our behalf, including payment processing, data analysis, marketing services, email campaigns, hosting services (third party data storage services), and customer service. Additionally, we may share with anti-cheat and anti-fraud companies the information required for our detection, investigation, and prevention of cheating in the Game and Terms of Service and EULA violations only for the purposes of detection, investigation and prevention of cheating in the Game. While providing the services for us, these companies may access your personal information, and are required to use it solely as directed by us for the purpose of our requested service;
c. Third Party game developers: We may share personal data with our third-party game developers. Such data includes but not limited to your game account ID, email address, in -game purchases, in game history or any blocking, in-game chats and language;
d. advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We share your email, username, game account ID, 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. These parties may act as our processors, or in certain contexts, independently decide how to process your information. In some instances, we do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 200 women aged between 40-50 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. We may also allow our advertisers to collect anonymous or aggregated information within our Services 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 Game and on the website of third parties, so that they can try to serve you with advertisement for services that are most likely to be of interested to you. Advertisers will also use this information to monitor, improve or modify their operations;
e. 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.
Your Internet browser can be set to reject cookies generally, or to provide notification whenever a cookie is sent to you. Note that we recommend you to allow all cookies from our Sites, otherwise some of our Services may work incorrectly and some features may become unavailable.
For further information about the names of the cookies used on our Site, the cookie provider, the purpose of the cookie and the cookie life cycle, please refer to our Cookies Banner/Policy.
If you wish to limit behaviorally targeted advertising, you can do so by limiting ad tracking in your device setting. Please note that opt-outs are specific to each browser and device, and it may take additional time before your opt-out choice will take effect.
You can opt-out of personalized advertising in our mobile Game applications by checking the privacy setting of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interested-based ads” (Android). You can adjust your mobile push notifications in your Android or iOS device settings menu.
12. YOUR RIGHTS
Under the General Data Protection Regulation, you have certain data protection rights when it comes to having access to your personal data, which you can exercise by contacting us at the email address provided below.
These rights are the following:
a. Right to be informed. Before data is collected, you have the right to know how it will be collected, processed and stored and for what purposes. This right is exercised through this privacy and data processing notification.
b. Right of access. You have a right to inquire and know what information we hold about you, how and why we use your information, to whom we disclose your information, and request a copy of the information we hold about you. In order to exercise this right, you should contact us at firstname.lastname@example.org and to identify which information you would like to receive. We shall get back to you in the fullest extent possible, however please note, that we might need to verify your identity before sharing the information with you, as well as that we might not be able to provide you with certain types of information if it is related to other users information Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why.
c. Right to correction/ Rectification. We put our best effort to keep the information that we hold about you accurate and up to date. Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process. In case you have reasons to believe that the information we hold is incomplete or inaccurate, please inform us at email@example.com and we will act accordingly.
d. Right to erasure / Right to be forgotten. We have to answer such right when:
• your personal data are no longer necessary in relation to the purposes for which we collected it
• withdraw your consent on which the processing is based and where there is no other legal basis for the processing
• your personal data have been unlawfully processed
• have to be erased for compliance with a legal obligation we are subject to
We reserve the right to refuse this right of immediate implementation if the processing is necessary for compliance with any legal obligation we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according Article 17 § 3 of the Regulation).
e. Right to restriction of processing of your personal data. You may have the right to request to block or suppress processing of your personal data, when certain conditions apply. If you would like to exercise this right, please contact us at firstname.lastname@example.org.
f. Right to data portability. In some circumstances, you have the right to request from us to move, copy or transfer to you, in a safe and secure way, in a commonly used and machine- readable format, the data which you have provided to us, in order to transfer it to another data controller. Whenever technically possible, this also includes the right to have the data transferred directly from us to another controller without you having to handle the data. If you would like to exercise this right, please contact us at email@example.com.
e. Right to object to processing / right to withdraw consent. You have the right to object to the processing of your personal data for specific reasons such as direct marketing purposes, purposes of historical/ scientific research or for the performance of a task in the public interest. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. After your request, we shall no longer process your personal data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms. If you would like to exercise this right, please contact us at firstname.lastname@example.org.
h. Rights related to automated decision-making including profiling. In some instances, our use of your personal data may result in automated decision-making, including profiling. Automated decision-making is the process of making a decision concerning you by automated means (using software algorithms) without any human intervention. For example, we use automated decisions to provide direct or targeted advertising on our Service. You can exercise your right to object to such processing or opt out of direct or targeted advertising as described below.
We do not carry out any decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects any user.
Additionally, you have the right to opt-out of direct marketing. Specifically, if you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
13. DO NOT TRACK SIGNALS
14. CONTACT US
For any questions regarding the processing of your personal data and the exercise of your rights mentioned above, you may contact us by telephone at +357 25 211 945 (working hours 09:00 - 17:00 Cyprus time zone), by e-mail at email@example.com and by post at: 16 Spyrou Kyprianou Avenue, Divine Clock Tower, 1st floor, 3070 Limassol, Cyprus.
In our webpage www.scorewarrior.com you may find a more extensive description of our Policy.