Last updated: 13.10.2023
- PERSONAL DATA, DATA CONTROLLER AND HOW TO CONTACT US
“Personal Data” refers to any data that relates to you as an identifiable individual. It may include your name, your address, your telephone number, your email address, your age, your gender, your game preferences, for instance. Anonymous information, which we are not in a position to relate to you, does not qualify as “Personal Data”.
Address: Väinö Linnan aukio 15, 33210 Tampere, Finland.
If you have questions about your Personal Data or data protection, you can reach us by email at email@example.com.
- WHY DO WE PROCESS YOUR DATA?
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect your data for some or all of the purposes described below, depending on the Services you decide to use and your choices when using them.
- To Perform a Contract
- To provide you with the Services, we process Personal Data necessary to:
- create accounts and enable you to use our Services and communicate with other users of the Services;
- operate the Services;
- license and deliver virtual goods and currencies (“Virtual Items”) you purchase and verify and confirm such purchases in the Services; and
- send you communications related to the Services.
- Legitimate Interests
To maintain and improve the Services to our users, we have a legitimate interest in collecting and processing your Personal Data to:
- develop and improve the Services and user experience;
- update and develop user profiles;
- handle your support requests, send or otherwise manage our relationship with you;
- customise your user experience (like language version); and
- provide you offers in the Services.
To keep our Services safe and fair and to fight fraud, we have a legitimate interest in collecting and processing your Personal Data to:
- analyse and monitor use of the Services and their social features;
- moderate chats and forums either automatically or manually;
- take action against fraudulent or misbehaving users; and
- prevent any form of harassment and cyberbullying.
We may provide you with relevant ads in our Services (including email) based on our legitimate interest in promoting and funding our Services. To do that, we may process your Personal Data to:
- track the content you access in connection with the Services; and
- deliver and improve advertising.
With your consent, we may process your Personal Data to
- track your activity in our Services to learn about your interests to improve and target advertising in our Services;
- send you newsletters or other similar communications if you have subscribed to them; and
- other purposes explained to you when we ask for your consent.
Finally, we may process your Personal Data as necessary to:
- comply with legal obligations that we believe apply to us; and
- protect your vital interests or the vital interests of another person.
In addition, we may process your Personal Data for additional purposes that are compatible with any of the purposes listed above.
We do not use your data to make automated decisions that significantly affect you.
- Data WE COLLECT
In relation to your use of our Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g., through our website’s technology or through our partners and contractors).
- Data We Collect Directly
We collect data in relation to your interaction with our Services for the purpose of providing the Services and to further develop the Services. In addition to Services-related data, we also collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information.
- User ID and Game Statistics
In order to access our games and some of our other Services, you are required to set up an Account and create a username with our distribution partner (e.g., Steam or PlayStation) (“Username”) and use that Username to log into our games.
Your Username is used to identify your user account with our distribution partner and keep your player progression in our games. Your Username is used as your public reference within our games without directly exposing your Personal Data.
To provide you with Services, we also need to collect, store and use various information about your activity in our games. Such information includes your Username, as well as what is usually referred to as “game statistics”, such as information about your in-game preferences, progress in the games, playtime, the geographical location you are accessing our games from as well as information about the device you are using.
- Content Data
- We may obtain your Personal Data when you register for and use our other Services, e.g., website forums, chats, or when you provide feedback about our Services. This data includes:
- information you provide when you register;
- your messages and other content you submit when you use the Services;
- information that you post, comment or like in any of the forums or social media groups owned or operated by Makea;
- information that you provide to us to become a participant in tests;
- information that you provide to us offering your partnership or services; and
- other information you choose to give us.
- Data We Collect Indirectly
We indirectly collect data through your interaction with and use of our websites and social media pages. This may include, but is not limited to, anonymised browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information (“Other Information”). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If Other Information is combined with Personal Data, we will treat the combined information as Personal Data.
- Data from Third-Party Services
- WHO CAN SEE YOUR DATA
- Other Users
Other users may, for example, see your Username and game activities, and read the messages you have posted to forums or social media groups.
- Partners Working for Makea
We have partners performing services for us. These partners process your data only at and according to Makea’s instructions in order to provide the Services. These external services can be, e.g., hosting, user support, analytics, and payment processing.
- Other Companies and Public Authorities
To combat fraud and illegal activity, we may exchange data with other companies and organisations and provide it to public authorities in response to lawful requests.
We may also disclose your Personal Data based on your explicit consent to comply with the law or to protect the rights, property or safety of us, our users or others.
- INTERNATIONAL DATA TRANSFERS
In connection with the processing activities described in this notice, your data may be transferred to and/or processed in countries outside the European Union (“EU”) and the European Economic Area. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data, as explained below. Adequate safeguards that our partners may use include standard contractual clauses approved by the EU Commission and other lawful safeguards.
- HOW DO WE PROTECT YOUR DATA
To help ensure a secure and safe user experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorised access or against loss, misuse or alteration. These security measures vary but may include, for example, encryption, pseudonymisation and limiting access to systems containing Personal Data.
- HOW LONG DO WE KEEP YOUR DATA
We retain your data for as long as your Account is active or as long as necessary to achieve the purpose(s) for which your data was collected. We may periodically delete or de-identify inactive Accounts or other data in our Services.
After the applicable retention period, we will either delete or de-identify your data. We may continue to use data that is not identifiable to you (for example, aggregate 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.
- YOUR RIGHTS AND OPTIONS
You have the following rights concerning your Personal Data:
- access the Personal Data we hold about you,
- correct or request deletion of your Personal Data,
- request us to restrict the processing of your Personal Data,
- object processing of your Personal Data to the extent our processing is based on our legitimate interests or the legitimate interests of a third party, or
- where technically feasible, request a copy of the Personal Data you have provided to us in a machine-readable format.
If you wish to exercise any of your data subject rights described above, please contact us by email at: firstname.lastname@example.org.
- YOUR OTHER RIGHTS
If the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. We may, however, continue processing your Personal Data despite your withdrawal of consent if we have another lawful basis to process that Personal Data.
To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message.
We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
Protecting children and their privacy is very important to us. Generally, our Services are not directed to children under 13 (or other age as required by applicable local law), and we do not knowingly collect any Personal Data from children under the age of 13. If we discover we are processing the Personal Data of a person under 13 years old, we will take appropriate measures to promptly delete the data from our records. If you have reason to believe we hold Personal Data relating to a user under 13, please contact us.