Last updated: 1 February 2023
In this Policy, “we,” “us,” and “our” means FunPlus International AG, Switzerland, a company registered in Switzerland whose registered office is at Bahnhofstrasse 2, 6300 Zug, Switzerland. This Policy deals with where we are acting as a ‘data controller’ under the data protection legislation: which essentially means where we are responsible for deciding what personal data we collect and how we use it. We also may operate as a ‘data processor’, meaning that we are processing personal data on behalf of another entity (for example a publisher of one of our games). When we refer to “Personal Data” we mean “personal” relating to you personally or from which you can be identified. Some of the information mentioned in this Policy is not “Personal Data” as is meant under data protection legislation, but we may refer to it to help you understand what we do.
We are committed to protecting and respecting the personal data of everyone we deal with – that is important to us and we know it is important to you.
In this Policy you will find information about what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find information about your rights and how you may exercise them.
If you are younger than 18 years of age, you must review this Policy with your parent(s) or guardian(s) and they have agreed to these terms on your behalf and take full responsibility for your compliance with them. A summary of this Policy, specifically written for young people, is available here.
Please read this Policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal data, you can reach us by email at firstname.lastname@example.org or by post at the above address.
You’ll find in this policy information about the following:
1. What information do we collect about you?
We will collect some information about you to enable you to play our games, to improve or optimise your gaming experience, to provide customer services, to improve the services we provide, and for marketing (see below for more details). This includes:
- Your contact information such as name and (if you choose to provide them) your phone number and email address;
- Your player username and password of your FunPlus ID;
- Your game profile – including your profile picture and any information needed for the game to function, such as an inventory of in-game items;
- Other data you choose to give us such as data to identify a lost or lapsed account such as the answer to a special question we may ask you in order to permit you to unlock or recover a lost or lapsed account;
- Data that you provided to us to verify your account;
- Your game user account or role ID(s) – FunPlus-specific ID(s) generated by our game server for you;
- Information about your payment orders;
- Analytics ID – a randomly generated anonymous identifier used to distinguish activity from one game account versus another in our analytics data;
- Third party account ID – for example, your account with Facebook, Xbox, Game Center, VK, WeChat, Google, Steam or PSN which you may use to sign into your game account, leverage your social graph, or integrate with third-party features (such as achievements);
- Usage data including information about how you use our website, products, and services, and your game progress;
- Your internet protocol (IP) address and mobile device identifiers (such as for example your device ID, advertising ID, MAC address, IMEI);
- Data to fight fraud (such as refund abuse in games or click fraud in advertising);
- Data about your device, such as device name and operating system, browser type, and language;
- Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences and it is at your full own discretion and control to adjust the settings on your device to turn off the function;
- Personal data that may be collected based on your explicit consent or our legitimate business interest for a specific purpose;
- Discord username.
2. How we collect information about you
We will collect this information in a variety of ways depending on how we interact with you.
|Direct interactions||You may give us your identity, contact, or other information by filling in online forms or by corresponding with us by post, phone, in-game, email or otherwise. This includes personal data you provide when you:
|Automated technologies or interactions
|As you interact with our website or our games we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. You can reject our collection of cookies through individual browser settings. Please see our Section 4 for further details.|
3. How we use your information
We use different information in different ways:
- To send you communications related to our services and games, answer your enquiries or deal with your complaints;
- Providing and managing our services including our games;
- Allowing you to participate in our website features;
- Verifying and confirming payments on FunPlus top-up center (where relevant interacting with third party payment providers);
- Account verification and clearance;
- Direct marketing letting you know about products and services that may be of particular interest to you;
- Administering surveys and opinion polls;
- Managing competitions and/or promotions and your registration for the same;
- Technical and usage information/analytics to help us develop games that our customers want to play and to improve them and to detect cheating and activities that ruin the experience of players using our games, security risks, fraud and other unlawful activity;
- The provision of social features as part of our services;
- Customising your personal experience;
- To send you related information such as updates, security alerts and support messages;
- On-site and in-app advertising and promotion of our goods and services and those of our service providers and trusted third parties;
- Website, system administration and account verification;
- Leader boards, Discord and community information, nicknames and club name/club information;
- To moderate communications between players either automatically or manually;
- To answer or satisfy legal or regulatory requirements; and
- When you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks (we encourage you to review the privacy notices/policies of these social networks to enable you to opt out of such activities).
We and our partners may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analysing trends, administering the websites, tracking users’ movements around the websites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
5. Legal basis for processing
There are a number of different legal grounds for processing personal data. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that:
- You have provided your consent to us using your personal data in that way (for example where you provide us with consent to send you marketing communications about our products and services); and/or
- Our use of your personal data is in our legitimate interest as a commercial organisation. For example, we are using cookies to track information about how our website is used in order to continually improve its layout based on how you and other users interact with its content, and to personalise it to the user (for example, by showing the content or a language which is relevant to your geographic location), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights; and/or
- Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your account); and/or
- Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation.
We generally do not collect or process any ‘special categories’ of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life, and sexual orientation). If this would apply, we will generally rely on obtaining additional specific consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information.
Protecting children’s privacy is of high importance to us. Our websites and our games are not intended for children under 13 years old and we do not knowingly collect data relating to children under 13. In respect of games that are not directed at children but which may nonetheless appeal to them, we take additional steps to limit access to our services based on the player’s age.
7. Sharing your information
The personal data you provide to us may be shared with third-party companies, agents, contractors, service providers, or our affiliated companies if this is necessary to provide you with our services, respond to your inquiries, or for any of the purposes described in this Policy. This may include:
- Our business partners and suppliers;
- Sub-processors who store or process the information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be ‘personal data’;
- Our auditors, insurers, lawyers, and other professional advisers;
- Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
- Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
8. Social Features
Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
Our games and services may include features from our partners, if any, such as social media interaction tools (and albeit not currently, in the future may also relate to in-game advertising). These partners, if any, may in such case, following your consent, access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices and opt out where you deem relevant.
9. International Data Transfers
FunPlus is operating globally and belongs to the global FunPlus Group. We may process and transfer your personal data to countries outside of the European Economic Area (EEA) where our group companies are located. We are aware that different countries may have different data protection laws, therefore, we will take steps to ensure adequate safeguards are in place to protect your personal data. FunPlus uses the European Commission’s standard contractual clauses. Standard contractual clauses are a set of contract terms approved by certain jurisdictions and deemed to provide adequate protections for cross-border transfers.
When we transfer your personal data to a third party in a country that does not offer adequate protections, we will make sure to protect your personal data by a) requiring that the third party applies the level of protection required under the applicable local data protection laws, b) requiring that the third party acts in accordance with our written instructions and our policies and standards and c) unless otherwise specified, only transferring your personal data on the basis of an appropriate contractual mechanism (such as the standard contractual clauses approved by the European Commission).
For further information about our international data transfers, you may contact the Privacy Office at email@example.com.
10. Your rights
Under EU data protection laws you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them insofar as we are able.
You have the right:
- To request access to or a copy of any personal data which we hold about you;
- To rectification of your personal data, if you consider that the information we are holding is inaccurate;
- To ask us to delete your personal data, if you consider that we do not have the right to hold it;
- To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- To ask us to stop or start sending you marketing messages as described below in the marketing section;
- To restrict processing of your personal data;
- To data portability (moving some of your personal data elsewhere) in certain circumstances;
- To object to your personal data being processed in certain circumstances; and
- To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with.
Any request from you for access to or a copy of your personal data must be in writing and sent to our Privacy Office firstname.lastname@example.org and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up-to-date, you have the option to fully control the data you shared with us, and you may update your information directly under your profile or adjust the settings on your device.
11. EU & UK Representative
If you have an unresolved privacy or personal data use concern that we have not addressed satisfactorily, please contact our EU and UK representatives or contact your local data protection authority.
For Data Subjects from the European Union, FunPlus has appointed FunPlus Games Spain SL, Carrer Casp 21, Pl. 5ª, 08010, Barcelona, Spain as its representative in the European Union, as required by Article 27 of GDPR which representative can be contacted through EUrepresentativeoffice@funplus.com.
For Data Subjects from the United Kingdom, FunPlus has appointed GRCI Law Limited as its representative in the United Kingdom which can be contacted through email@example.com. Please include “FunPlus International AG” when contacting our UK Representative.
If you have accepted to receive notifications for a certain game, we may use your personal data to send you tailored suggestions, offers, or auction information about the game. For personalised in-game offers opt-out, you can use the options provided in the game settings. You can easily turn off the notification in each different category within the game or opt-out from receiving notifications or alerts on your device.
You can opt-out of interest-based advertising on mobile applications, if any, 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).
13. How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out in this notice or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date, and still required.
By law we have to keep basic information about our customers (including contact, identity data, (and financial and transaction data relating to transactions via our store, if any)) for six tax years plus the current tax year after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see “Your rights” for further information.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you opt out from marketing, we may retain the necessary information to enable us to respect your wishes to not be contacted for marketing purposes.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.
15. Links to Other Sites
16. Additional Information for California; United States Residents
In this section, FunPlus provides additional information about how we handle personal data about California residents as required by the California Consumer Privacy Act of 2028 (CCPA) as amended by the California Privacy Rights Act (CPRA). The information enumerated in this section is in addition to and does not replace the information under this Policy.
- No sale of personal data
FunPlus does NOT sell your personal data to any third party to provide the game or game service described in this Policy. FunPlus also does NOT sell personal data of players who we know are younger than 16 years old.
- Personal data disclosure
FunPlus may share your personal data with third parties as described in the “Sharing Your Information” section above. Our third-party companies, agents, contractors, service providers, or our affiliated companies who work with us may have access to your personal data in order to provide you with the services within the time limits and throughout the duration of the agreements. FunPlus ensures that our service providers cannot use your personal data for any other purposes than what has been instructed by FunPlus.
In the preceding 12 months, FunPlus has disclosed the following categories of personal data as part of our services:
- Additional rights under CCPA
- Right to opt out of the sale or sharing of personal data and limit the use of sensitive personal data.
Under the CCPA, you have certain opt-out and limitation rights. You have the right to opt-out of the sale of your personal data, you have the right to opt out of the sharing of your personal data for cross-context behavioural advertising purposes, and you have the right to limit the use of your sensitive personal data.
- Right to non-discriminate for the exercising of privacy rights.
- Right to opt out of the sale or sharing of personal data and limit the use of sensitive personal data.
You will be free from discrimination for exercising any of your rights under the CCPA.
To exercise your rights under the CCPA, please submit your request by email to the Privacy Office at firstname.lastname@example.org.
Questions, comments, and requests regarding this Policy are welcomed and should be addressed to FunPlus International AG, Bahnhofstrasse 2, 6300 Zug, Switzerland, or by email to email@example.com.
18. Changes to this policy
Any changes we make to our Policy in the future will be posted on this page and, where material and appropriate, notified to you by in-game message. We urge you to check regularly to see any updates or changes to our Policy.
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