f
s
All games Lords of the Arena LEGAL DOCUMENTATION

PRIVACY POLICY

MY.COM LORDS OF THE ARENA PRIVACY POLICY

 

Last updated: June 6, 2019

 

  1. Who we are

1.1.    We are My.com B.V. located at Barbara Strozzilaan 201, 1083HN, Amsterdam, the Netherlands.

1.2.    This Privacy Policy sets out how we collect and use your personal information when you use the Lords of the Arena social network game ("Game Services") offered by My.com B.V. and its subsidiaries on the Facebook platform (https://www.facebook.com/) and the choices available to you in connection with our use of your personal information (the Privacy Policy).
This Privacy Policy should be read alongside, and in addition to, our Terms and conditions (accessible online at https://support.my.com/games/kb/lota/tou) (Terms). In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

 

  1. This Privacy Policy

2.1.    By making available the Game Services we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use the Game Services;
(b) provide true information about yourself to the extent necessary for use of the Game Services;
(c) understand that by the posting your personal information where it is accessible by other users of the Game Services you have manifestly made this information public, and this information may become available to other Game Services users and internet users, may be copied and disseminated by them;
(d) understand that some types of information transferred by you to other Game Services users cannot be deleted by you or us;
(e) are aware of and accept this Privacy Policy.

2.2.    We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

 

  1. Information we collect about you

3.1.    In order to implement the agreement between you and us, and provide you with access to the use of the Game Services, we will improve, develop and implement new features to our Game Services, and enhance the available Game Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2.    We set out in more detail the information we collect when you use our Game Services, why we collect and process it and the legal bases below.

 

Information Collected

Purpose

Legal Basis

1

Data you provide for registering in the Game Services with your Facebook profile, including profile picture, name, gender, age, country and list of your friends.

 

We use this information in order to create your player accounts and allow you to play the game, to manage and administer the Game Services provided to you.

We use this data to enable us to fulfil our obligations to you as part of the Game Services (e.g. in cases where you request restoration of your account).

We use this information for certain social functions of our Game Services, such as to show you who of your friends play the same game as you, to allow you to invite your friends to join the game and to give you the ability to share your game progress in your social network profiles.

 

Legitimate interests

Performance of our contract with you

 

2

Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and another additional data that you may provide us, including through our support service.
We may take additional verification steps where we consider reasonable in order to verify your account.

 

We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights.
For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.

 

Legitimate Interests

 

3

Information that is created by you while using the Games Services (including information that you post in any game chat rooms). Depending on the place of posting this information can be available to some or all other users of our Game Services.

 

We use this information in order to manage and administer the Game Services, including providing our Game Services to you, and to enable players to communicate with each other.

 

Legitimate interests, which inter alia, include the processing of manifestly made public by you data where it is accessible by other users of the Game Services

Performance of our contract with you

 

4

Information that is created by you while placing requests to our Game Services support.

 

We use this information in order to verify your identity (e.g. via player ID) and to fulfil your support request.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

 

Legitimate interests

Performance of our contract with you

 

5

Information that is generated as the result of your behavioural actions when using the Game Services (such as when and for how long you play, game features and other players you interact with, purchases you make, progress or levels you achieve, participation in player clubs, in-game events and other gameplay activities). This information can be available to other users of our Game Services (e.g. on Leaderboards).

 

We use this information in order to:
to manage and administer the Game Services including providing our Game Services to you, to improve and optimize the game and your experiences in the game,

to communicate with you, including via in-game updates and notifications, about new features, and promotional offers that we think might be of interest to you,

to administer promotional activities or in-game events sponsored or managed by us or our partners.

 

Legitimate interests

 

Performance of our contract with you

 

6

Information that is received about you as the result of other users’ actions on the Game Services (in particular, information posted in chat rooms by other users).

 

We use this information in order to manage and administer the Game Services including providing our Game Services to you.

 

Legitimate interests

 

Performance of our contract with you

 

7

Payment data

 

When you play our game on Facebook platform, any purchases you make will be processed by Facebook and subject to its own terms of service and privacy policy. For these purchases, we do not receive your financial data, but may receive non-financial information related to your purchases, like your name and the items purchased.

 

Legitimate interests

Performance of our contract with you

 

 

3.3.    Our legitimate interests include (1) maintaining and administrating the Game Services; (2) providing the Game Services to you; (3) improving the content of the Game Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Game Services; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.

3.4.    As part of maintaining and administrating the Game Services we use the information to analyse user activity and ensure that rules and terms of use for the Game Services are not violated.

3.5.    Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.6.    Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Game Services.
Once you have provided this data it will be accessible by other site users and it becomes difficult for us to remove this data.

3.7.    If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

 

  1. Data sharing

4.1.    Your Facebook friends who also play our Game Services will see your name, photo, player profile and descriptions of your in-game activity.

Other players (not being your Facebook friends) will be able to see your player profile; view descriptions of your in-game activity; communicate with you within our Game Services and send you game requests or friend requests through our Game Services.


We take technical and organizational measures to ensure that your data is safe. Please note that by the posting your personal information you have manifestly made this information public where it is accessible by other users of the Game Services, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.

4.2.    We may share your data with MGL MY.COM (CYPRUS) LIMITED and other our affiliates to perform services like analytics, analysis, customer service and marketing optimization. Sometimes we may also need to share your data with a third party in order to provide our Game Services to you or to administer the Game Services, for example if you choose to share your data across other social media platforms.

4.3.    We will also share your data with Facebook, as our platform partner, who assist us in delivering and optimizing our Game Services.

 

  1. Privacy Settings

5.1.    You can customize your Facebook profile privacy settings via https://www.facebook.com/settings page.

5.2.    The Game Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

5.3.    We bear no liability for the actions of third parties which, as the result of your use of the internet or the Game Services, obtain access to your information in accordance with the confidentiality level selected by you.

5.4.    We bear no liability for the consequences of use of the information which, due to the Game Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site.

 

  1. International Transfers

6.1.    We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.

6.2.    The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

 

  1. Retention Periods

7.1.    We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2.    You may delete your personal data by removing the data from your Facebook and/or in-game account; alternatively, you can delete your Facebook and/or in-game account.

7.3.    We may remove your in-game account, or the information you post as provided by the Terms.

 

  1. Your Rights

8.1.    You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.

8.2.    If you would like to exercise these rights, please contact us via Facebook message at https://www.facebook.com/Lords-of-the-Arena-382420099038040/ or send your request to us, in writing to Barbara Strozzilaan 201, 1083 HN, Amsterdam, the Netherlands. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

 

  1. Security Measures

9.1.    We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

9.2.    Access to the Game Services is authorized using your Facebook account. You are responsible for keeping your login and password of the account confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.

9.3.    We urge you to log out of your account and any social network account you have used to access the Game Services when you are finished using them.

 

  1. Changes to this Policy

10.1.                    From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

 

  1. Contact Us

11.1.                    If you have any questions, please send your inquiries to us via Facebook message at https://www.facebook.com/Lords-of-the-Arena-382420099038040/ or in writing to Barbara Strozzilaan 201, 1083 HN, Amsterdam, the Netherlands. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

11.2.                    All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

11.3.                    The e-mail address of our DPO is dpo@corp.my.com.