“Personal data” is data that we may collect directly from you, or indirectly through a visit on our website or while you play one of our games. You will find hereafter in this Policy a list of personal data we may collect from you, why we collect it, how we use it, how we store it, how we transfer it, as well as a way to contact us should you have questions about your data or would like to assert your rights. We only collect, use, store and transfer (“process”) your personal data in accordance with the applicable data protection laws, including, but not limited to, the General Data Protection Regulation (EU) (2016/679) (“GDPR”) and the applicable national data protection legislation (hereafter “applicable law”).
Depending on whether you are a website visitor, customer and/or a user of our Services, we will process personal data such as your contact details (email address, telephone number and postal address), your username, password(s) and payment details. We will also collect and use data about your technical equipment such as your hardware and software type and location data (to determine which age-rating to display as well which customer rights apply), and other data you provide us with, for example when you sign up for our surveys and contests. For more information about the personal data we collect, use and otherwise process, please see section 6 below. We will use your personal data for different purposes. We will for example use the data to provide you with the Service you have requested, to improve our games and other Services, to predict user trends, to make recommendations based on your usage, to process payments and customize our Services to you. For more information about how we use your data, please see section 7 below. We will engage other companies in order to fulfil our purposes and obligations as set out in this Policy, and we will transfer your personal data to countries outside the EU and EEA that may not have as strict privacy legislation as where you live. We will only transfer your personal data to such countries if we are allowed to do so, please see section 8 for more information. When we collect personal data about you, you are entitled to the following rights under applicable law: - the right to access and rectify your personal data; - the right to object to our processing of personal data; - the right to restrict to our processing of personal data; - the right to demand us to delete your personal data; and - the right to data portability. For more information about the rights you have in relation to your personal data, please see sections 14- 20 below. If you have any concerns as to how we use your personal data, we would kindly ask you to contact us first. However, you can always lodge a complaint with a relevant authority, specifically where you live, work or where you believe an infringement of your rights has occurred. The relevant data protection authority in France is CNIL (Commission Nationale de l’Informatique et des Libertés), www.cnil.fr. Please see section 22 for further information.
If you have any questions about the personal data we collect, how we use your data and how we transfer your data to fulfil our purposes as stated herein, please contact us via post at : ENODO GAMES SAS 121 avenue des Champs-Elysées 75008 Paris, France.
1. WHO WE ARE
We are ENODO GAMES SAS. This Policy applies to websites operated by us. We are the controller of the personal data collected. If you have any questions or want to know more about how we use your personal data, please contact us as indicated at the beginning of the Policy.
Our postal address can be found at the end of the Policy, under the section HOW TO CONTACT US AND HOW TO COMPLAIN.
2. WHAT WE PROMISE
We promise to keep your data safe and to not to sell your data to third parties. We promise to give you the right to access and delete your data, and to provide you with ways to manage and review your marketing choices as well as any other information (such as for example newsletters) you get from us. Please see sections 14 - 22 for more information.
3. WHAT PERSONAL DATA IS
Personal data can be any data relating to an identified or identifiable natural person. In other words, it can be any data that could allow us to identify you both directly and indirectly (like for example your name, email address, IP address, or your billing address). In this Policy, we will use the word “data” to refer to personal data.
4. LEGAL GROUNDS FOR PROCESSING YOUR DATA
We will only use and process data about you if we have one of the following reasons to do so: - to fulfil a contract we have with you (for example, when you have purchased a game on our ENODO GAMES Store); - when it is our legal duty (for example, to identify your age and make sure we are not collecting data from young children, for book keeping purposes and to fulfil our obligations in relation to authorities); - when you consent to it (for example, when subscribing to our newsletter or opening an ENODO GAMES Account); or - when it is in our legitimate interest (for example, to enforce our policies, manage our everyday business, to perform statistical analysis on anonymized and/or aggregated data, for direct marketing purposes, to ensure information security, to prevent fraud or to transfer the data to different part of the organization when necessary). When we rely on a legitimate interest we have concluded that our interest is not overridden by your interests or fundamental rights and freedoms. You are welcome to contact us to learn more about how we have reached this conclusion.
5. WHEN DO WE COLLECT YOUR DATA?
We will collect data about you when you use our Services, including in the following situations: - When you register an ENODO GAMES Account; - When you subscribe to our newsletters; - When you purchase one of our games or any other products; - When you play our games; - When you register on and use our forums; - When you contact us or our support services, via emails or letters; - When you use our websites, in-game browser, apps, or games; - In customer surveys; - If you participate in user research initiatives; - If you participate in a playtest or prelease test such as alpha/beta/etc. test releases; - If you take part in our competitions or promotions; - When you enroll in, or participate in, one of our events; - When you send us a game pitch; - When you click on one of our ads or in our newsletters; - When you subscribe to receive our press releases; When you log in to our Services using third party account; When you work for ENODO GAMES. In such case, please contact our Human Resources department separately for more information.
6. WHAT DATA DO WE COLLECT?
We use data that you have explicitly provided to us in different situations. We also use personal data that is generated by your device or when you use our Services. These categories are further explained below. Data that you explicitly provide us with: - email address; - username; - country of residence; - age or date of birth; - name; - password(s) created to access parts of the Services; - nicknames on forums and in games.
The above information may be provided to us when you open an ENODO GAMES Account, or when you subscribe to our press releases or newsletters. In addition to the above, and when purchasing a game or enrolling in an event, you may have to provide us with the following data: - postal address; - telephone number; - card information payment account details; - PayPal account information; - name and contact information for a business or organization.
We will always ask for your consent to give us details on your location data. You have a right to withdraw your consent at any time as described under section 20 below.
If you own any of our games on Steam and have posted reviews about the game on Steam, we may also collect such reviews, including your Steam ID, and add it to the data we receive from you or already have. This is done to better analyze who is our customer and what you as a customer want from our games.
7. WHY DO WE USE YOUR DATA?
We will not use your data for any other purpose than the purpose for which the data is originally collected.
Special information about marketing: We use your data to inform you about relevant products and offers, e.g. provide you with targeted marketing. The data we collect in such cases contain information that you willfully provide us with, the data we collect when you use our Services or from third parties we work with. We analyze this data to form a view on what we think you might want or need or what may be of interest to you. You can at any time object to our use of your personal data for marketing purposes, including any profiling for such purposes, and we will then stop using your personal data for such purposes. Please see section 22 for our contact details.
8. WHO DO WE SHARE YOUR DATA WITH?
To be able to provide you with the Services and the best possible experience, we will share your data with other companies and organizations. We will only do so if our partners can provide the same level of security to keep your data safe as implemented by us and if our partners can ensure that they comply with applicable laws and privacy regulations.
For Services using the Unity Engine, such as for example our game The Architect : Paris, Unity is our service provider. We may release your data when we are required to by a court order, according to law or in the event of a bankruptcy or other similar unfortunate event. We may also share and may acquire your data with future subsidiaries or companies if we choose to sell, transfer or merge parts of our business. We will, however, only transfer the data if we must and if these companies comply with applicable privacy regulations and can guarantee that your data will be kept safe.
9. CAN CHILDREN USE OUR SERVICES?
Our Services and games are not directed to children and we do not knowingly collect data from children under 13 years of age. We strongly recommend parents or guardians to instruct their children to not disclose any data when online. Parents or guardians who are concerned about the transfer of data are welcome to contact us at email@example.com. If we obtain actual knowledge that we have collected data from a child, we will promptly delete it, unless we are legally obligated to retain such data.
ENODO GAMES will use the following cookies on our websites, for the following purposes:
a) Strictly Necessary Cookies: These cookies are necessary for the website to function. They are usually set in response to actions made by you which amount to a request for services, such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the website might then not work. These cookies do not store any Personal data.
b) Performance Cookies: These cookies allow us to count visits and traffic sources in order to measure and improve the performance of the website. These cookies help us to know which pages are the most and least popular and how visitors move around the website. All data these cookies collect is aggregated and therefore anonymous. You can set your browser to block or alert you about these cookies, as explained hereunder. If you do so, we will not know when you have visited our website, and will not be able to monitor its performance;
c) Functionality Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services have been added to the website. If you do not allow these cookies, some or all of these services may not function properly;
Please note that most web browser applications (such as Microsoft Edge, Mozilla Firefox and Google Chrome) have features that can notify you when you receive a cookie or prevent cookies from being sent. In Microsoft Edge, you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector. In Firefox, you can adjust your cookies by clicking "Tools", "Options" and "Privacy". In Google Chrome, you can also adjust your cookies by clicking on "Settings", "Show advanced settings", "Content settings" and on the "Privacy" section. If you disable cookies, however, you may not be able to use certain personalized functions of the website.
11. SECURITY MEASURES TO PROTECT YOUR DATA
We maintain physical, electronic and procedural safeguards to help guard your data in compliance with applicable privacy regulations. If transactions are offered on the Services, transaction information is transmitted to and from the Service in encrypted form using industry-standard Transport Layer Security (TLS used to be known as SSL) connections to help protect such data from interception. We strictly restrict authorized access to your data only to those persons who have a legitimate purpose to access it. We also have security measures in place to protect the loss, misuse and alteration of the data we process. We encourage you to be careful when sharing your data with other users when you use our Services like forums or chats. ENODO GAMES will NEVER ask for your password to be sent separately or in clear text. Anyone doing so is probably trying to steal your data.
12. IF YOU CHOOSE TO NOT SHARE YOUR DATA WITH US
We may need to collect data to be able to fulfil our legal obligations or fulfil the terms of a contract we have with you or to be able to even present you with the Services. If you choose not to give us this data, it may prevent us from meeting our obligations. It may also mean that we cannot perform the Services needed to run your ENODO GAMES Accounts or policies. It may also mean that we have to cancel a product or Service you have with us or that you will even be unable to play certain parts of our game such as multiplayer. Any data collection that is optional will be clearly indicated as such at the point of collection.
13. HOW LONG DO WE KEEP DATA?
We will keep your data for as long as you are a player or customer of ENODO GAMES. We may keep your data for longer for research or statistical purposes. If we do, we will make sure your data is anonymized and non-traceable to you as a person. We will also keep it for longer if we cannot delete it for legal or regulatory reasons. We will however delete all data that is no longer necessary after a reasonable period. For example, any inactive ENODO GAMES Account will after a period of two (2) years be deleted unless they contained games or other products you have purchased as we assume you would rather not have them deleted. We will also delete data upon request. For more information, please read section 18 of this Policy HOW TO GET OR RECEIVE A COPY OF YOUR DATA.
14. ACCESSING, CHANGING AND UPDATING YOUR DATA
When you use our Services, we strive to provide you with ways to quickly update or delete data that you have actively provided. You have the right to access the data relating to you. This includes the right to be informed whether or not data about you is being processed, what data about you is being processed, and the purpose of the processing. You also have a right, upon your request, to access data about any evaluation or assessment of the balancing test we are required to conduct when we process your data based on our legitimate interest. Furthermore, you have the right to rectify or add data if the personal data is inaccurate or incomplete. As soon as we become aware of any inaccurate personal data being processed, we will always rectify your data without undue delay and notify you accordingly. If you have created an ENODO GAMES Account, you can access, change and delete some of the data provided on your profile by logging in to your ENODO GAMES Account at firstname.lastname@example.org.
15. RIGHT TO OBJECT TO THE PROCESSING OF YOUR DATA
You are also entitled to object to the processing of your data on grounds related to your particular situation. Please note however, that we must still process some personal data about you to provide the Services to you. This means that you cannot object to all our use of personal data and still require us to provide Services to you.
You may unsubscribe to newsletters you have previously opted-in to, by following the instructions in the newsletter you receive (please see further information below).
16. RIGHT TO ERASURE
You are entitled to request that we erase data related to you. We will erase your data upon request provided that it is no longer necessary for the purpose we collected it for (for example you cannot require all personal data about you to be erased and still receive Services from us), and that we have no legal obligation to store personal data.
17. RIGHT TO RESTRICTION
You are entitled to require us to restrict our processing of your personal data if you contest the accuracy of the data, if the processing is unlawful but you do still not want us to erase the data, if the data is no longer needed to fulfil the purpose it was collected for or you have informed us that you do not consider us to have a legitimate interest for certain processing.
18. HOW TO GET OR RECEIVE A COPY OF YOUR DATA
You can access a copy of your data by contacting our Support department at : email@example.com. If you request access to personal data about you that you yourself have provided and (i) if the personal data is being processed automatically and (ii) in accordance with a contract between you and ENODO GAMES or based on your consent, you may request that the data is provided in a structured, commonly used and machine-readable format and you may also request that the personal data is transmitted to another controller, if this is technically feasible.
19. HOW TO ASSERT YOUR RIGHTS
You can contact our Support department at firstname.lastname@example.org any time to get a list of all the data we have collected from you or to get such data deleted or invoke your other rights as explained above. We will do our bests to answer your request in a timely manner but please note that it may take a couple of days. Thank you for your patience and understanding. Please note that if we cannot identify and guarantee who you are, we might ask you to provide us with additional information or log into your ENODO GAMES Account if possible. Please note that we will not delete any data if we are unable to verify that you are their rightful owner. We will however always use our best effort to help you out.
20. HOW TO WITHDRAW YOUR CONSENT OR CLOSE YOUR ACCOUNT
This Policy may change from time to time. Any changes to this Policy will be posted on this page. If the changes are significant, we will provide you with a more noticeable notice, like for example by email or on your ENODO GAMES Account page. If you are asked to accept material changes to this Policy and decline to do so, you might not be able to continue using the Services with all functionality preserved.
22. HOW TO CONTACT US AND HOW TO COMPLAIN
Please let us know if you want to issue a complaint by contacting us at : email@example.com. We will also appreciate to get feedback from you if you think that this Policy or any part of it is unclear. Our postal address is: ENODO GAMES SAS 121 avenue des Champs-Elysées 75008 Paris, France.
You always have the right to lodge a complaint with the relevant authority in particular where you live, work or where an alleged infringement of the GDPR has occurred. For example, the relevant authorities in France is CNIL (Commission Nationale de l’Informatique et des Libertés) https://www.cnil.fr .