PRIVACY POLICY
This Privacy Policy ("Policy") explains how personal data is collected, stored, used and disclosed by Incineration Productions AD ("Incineration Productions", "us," "we," "our") when you use or access the VR action game, SpellPunk VR / SpellPunk and its respective webpage (the “Game”), as well as when you communicate with us.
The Controller of personal data, within the meaning of GDPR, is Incineration Productions, а joint-stock company duly incorporated under the laws of Republic of Bulgaria, UIC: 205302517, having its seat and business address at 31 Layosh Koshut Str., entr. A, floor 3, apt. 3, Sofia, Bulgaria. Email: hello@incineration.games. Incineration Productions abides by applicable privacy legislation and processes the personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and our internal rules for personal data protection.
Incineration Productions develops video games across multiple platforms. With this development, we collect information from our customers, visitors, and users ("you," "your," "user," "users") of the games and related websites. This Policy only applies to the SpellPunk VR Game and its webpage, and therefore is not applicable to any third-party websites you may link to from Game or its webpage. If you follow a link to any of these websites or use third party services, you should be aware that they have their own privacy policies and that we do not assume any liability for their processing of your personal data. Therefore, please make sure to read their privacy policies before providing your personal data to them.
In order to play our Game and visit its webpage, you need to read this Policy and to agree to our collection, storage, use, disclosure, and deletion of your data as outlined in this document. This Policy has been constructed to ensure SpellPunk VR webpage and playing the Game. We ask that you take a moment to read this Policy carefully and become aware of its content. If you have any questions, you are welcome to contact us by using the contact information provided in the Policy.
PLEASE NOTE THAT THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME, SO PLEASE CHECK BACK REGULARLY TO STAY INFORMED OF ANY CHANGES. IF WE CHANGE THIS PRIVACY POLICY IN A WAY THAT WILL AFFECT HOW WE USE YOUR PERSONAL DATA, WE WILL ADVISE YOU OF THE CHOICES YOU MAY HAVE AS A RESULT OF THOSE CHANGES.
Once we change the Privacy Policy, it will become legally binding 30 days after we post it online. Unfortunately, if you do not agree to those changes (regardless of whether you email us), we must then ask you to cease using our Game.
THE INFORMATION WE COLLECT. HOW WE COLLECT YOUR DATA
Incineration Productions respects the privacy of its online visitors and recognizes the importance of protecting the data collected about you.
SpellPunk VR Game could be accessed through the online platform Steam /https://store.steampowered.com/, offered by Valve Corporation (“Valve”) or through the online platform Viveport, offered by HTC Corporation (“HTC”).
Your subscription with Steam platform requires provision of certain information to Steam that typically includes email address, user-created name (Steam User ID), password, information on your age and others. Completion of Steam’s registration process usually requires provision of certain Transaction and Payment Data, as indicated in Steam’s Privacy Policy Agreement /https://store.steampowered.com/privacy_agreement/. Steam acts as data controller with respect to this information that you directly provide upon subscription and account completion and in no way this information is shared or transferred to us at the moment of your subscription with Steam.
When you access SpellPunk VR Game, Incineration Productions only get access to your user-created name (Steam User ID) and we act as data controller with respect to this information you share with us when using the SpellPunk VR Game.
When using the Game, you may be involved in SpellPunk events such as multiplayer tournaments and others. In these cases, certain data may be collected by Incineration Productions where we also act as data controller with respect to this information. This data may include:
For Steam:
• Steam User ID
• Steam display name
• Steam avatar
• Country of residence
• Steam currency settings
• VAC trust status
• Log of user activity within SpellPunk (including, but not limited to: login time, logout time, log of matches played, number of wins and losses, gathered experience and loyalty points, events)
• Matchmaking Rating (MMR)
• IP address
• Country (identified based on IP address)
• Any other data which you supply us via our services
Your subscription with Viveport platform requires provision of certain information to Viveport that typically includes email address, user-created name (Account ID), password, information on your age and others. Completion of Viveport’s registration process usually requires provision of certain Transaction and Payment Data, as indicated in Viveport’s Privacy Policy Agreement /https://www.htc.com/us/terms/privacy/. HTC acts as data controller with respect to this information that you directly provide upon subscription and account completion and in no way this information is shared or transferred to us at the moment of your subscription with Viveport.
When you access SpellPunk VR Game, Incineration Productions only get access to your user-created name (Account ID) and we act as data controller with respect to this information you share with us when using the SpellPunk VR Game.
When using the Game, you may be involved in SpellPunk events such as multiplayer tournaments and others. In these cases, certain data may be collected by Incineration Productions where we also act as data controller with respect to this information. This data may include:
For Viveport:
• HTC Account ID
• Account display name
• Account avatar
• Country of residence
• Account currency settings
• VAC trust status
• Log of user activity within SpellPunk (including, but not limited to: login time, logout time, log of matches played, number of wins and losses, gathered experience and loyalty points, events)
• Matchmaking Rating (MMR)
• IP address
• Country (identified based on IP address)
•
Any other data which you supply us
via our services
In the course of the Game, we may collect and process certain additional information for, such as:
· preferences and settings including communication or content restrictions and parental control settings;
· other account information such as language selection, any dates the foregoing data is modified;
· any other information relating to the user’s account, as well as any information relating to the user’s play or use of the Game, including of the user’s gameplay statistics, preferred strategies, trends, history of technical issues and support usage
When you ask for user support, or contact us for any reason, certain data might be collected by Incineration Productions where we also act as data controller with respect to this information. This data may include:
· data collected in crash logs that are gathered by your device or the technical parameters of the device you use to play SpellPunk VR;
· any other information you choose to provide when contacting us.
When you choose to participate in online surveys, supported by Incineration Productions, you may be asked to voluntarily provide us with personally identifiable data that may include your name, email address, user name, birthday, demographic information, game experience, hardware specs, hobbies, occupation, platform preferences, additional contact information, and other game-related information. However, there will be no consequences for you if you refuse to give us such data.
You may choose to subscribe for marketing communications and newsletters about our new and interesting games and merchandising products, upcoming events and etc. when you will be asked to voluntarily provide us with personally identifiable data such as first and fast Name, country and mail address.
In order for you to play SpellPunk VR or access other services, we need to process the data described above. In case you do not agree to provide us with the above-mentioned data or particular part of it, you may not be able to play SpellPunk, or take part in events and tournaments or use other services, as applicable.
Third parties who provide advertising and related services may give us your personal data, these including analytics providers and ad networks.
Please remember when you are using support, forums, or purchasing merchandise/in game credits packages, you are dealing with a third-party. You may be asked to provide payment information, such as a credit card number, holder name, and holder address. That data will remain with said third-party and be applicable to their Privacy Policy. We do not have access to information related to your credit card and / or its identification. However, we may share personal information, such as the names of users, with trusted third-party service providers for reasons such as for order purposes/order statuses.
By accepting this Policy, you are confirming you are also agreeing that all data provided by you is true and complete. If believed otherwise, we reserve the right to delete your account.
As of March 2020, this is all the data we collect. As we roll out the next stages of SpellPunk VR, this portion of our privacy policy will be amended as necessary.
HOW DO WE HANDLE YOUR PERSONAL DATA
Safeguarding your personal data is a priority for us. The data we collect from you is stored on our secure servers – only if necessary – by those of our trusted partners. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. Your personal data may only be accessed by our employees, agents, contractors and other third parties who need to access it and are bound by a duty of confidentiality. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Although we work hard to protect your personal data, we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal data. However, we maintain security and incident response plans in the event of a physical or technical incident to handle this in a timely manner and limit any negative effect of such incident.
How long are we going to store your data? We will retain your personal data only for as long as needed in order to fulfil the purposes outlined in this Privacy Policy, to provide our services with respect to the Game.. In certain special cases, a longer retention period might be required by law, such as for tax reasons, accounting purposes or other legal requirements and obligations.
When we will no longer require your personal information in order to provide our game related services to you, we will either delete it or anonymize it. In particular:
1. we will keep data that is associated with your SpellPunk VR account for the duration of the agreement to access SpellPunk services (i.e. until you close your SpellPunk account and request deletion). Following account closure, limited data that we collect about you will still be retained for up to 3 (three) years for tax, legal and accounting purposes;
2. if you contact us and don’t have a SpellPunk VR account, we will retain correspondence with you as long as necessary to assist you, followed by a period necessary for legal or accountability purposes;
3. for marketing purposes, we will store data as long as we have valid consent, and we will delete or anonymize it without undue delay and no later than within 30 days from the moment we receive a request to unsubscribe.
HOW WE USE THIS INFORMATION AND ON WHAT GROUNDS
LEGAL BASIS FOR DATA PROCESSING. We process your data for the purposes of fulfilling our contractual obligations and provide you with access and allow you to play SpellPunk VR and administrate your account, provide you with the Game content, maintaining your account, debugging and technical support, and contacting you with information about the licenses and legal terms of use of SpellPunk VR as we produce more content or change the Game.
We may also use your data for some or all of the following purposes, to support our legitimate interests, consistent with your rights and preferences, we use personal information:
· to communicate with you, respond to your requests, or provide you with updates and information;
· to better understand our users, their interests, and their preferences;
· to personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;
· to develop, deliver, and improve our Game, services, and other offerings, some of which may be offered in partnership with other parties;
· to manage and customize advertisements or promotional offers;
· for security purposes;
· for internal purposes such as auditing and data analysis.
· to conduct surveys in order to improve your interaction with our Game;
· to carry out analysis on an aggregated level to improve Game;
· to ensure enjoyable gameplay through the analysis of players’ data;
· to maintain the ranking of SpellPunk VR’ players;
· to calculate conversion rates and other elements of SpellPunk VR’ performance
· to organize official events and award points to participants of third-party events, in which you have elected to participate;
· to maintain technical support services for game users;
· to identify incidents of game misuse;
· to maintain, improve or develop SpellPunk VR
Further, we may process your personal data to provide services that are subject to terms you have accepted, such as enforcing our licenses, agreements, and terms of service, which may include reasonable monitoring to detect and prevent misuse or fraud and to keep our Game fair for all users.
We may process your personal data to comply with legal obligations, such as:
· for tax, legal and accounting purposes;
· for the accountability purposes as defined by EU legislation (GDPR).
For other purposes, we will ask for your consent and you will be entitled to withdraw this consent at any time with no impact on the validity of the processing before your consent has been withdrawn. For example, we will process your personal data for marketing purposes only to the extent you have explicitly consented to this.
The anonymous data we collect is unidentifiable and used for the sole purpose of analytics. We may use IP addresses to troubleshoot problems. Traffic and other anonymous/non-personal identifiable data may be shared with potential business partners and advertisers in an aggregated format.
Incineration Productions may use aggregate or anonymous data which will not be linked to identify individuals for various other uses for it and/or third parties.
WHO WE SHARE THIS INFORMATION WITH
We may disclose your personal data to our independent contractors and business partners who have agreed to (i) hold this information in confidence, and (ii) not use it for any purpose except to carry out the services they are providing to us. Such contractors and business partners include those hosting our services or other data; managing the functionality of our services; hosting customer relationship management, marketing automation, customer service and other software platforms on our behalf; assisting with marketing and promotions; enabling us to send you email, provide accounting, legal and financial services; provide customer services, process customer inquiries and perform other statistical analyses; or are members of our group of companies. We may also share information collected about you with third parties who we partner with for advertising campaigns, contests, special offers or other events or activities in connection with our services.
We may also disclose your personal data to third parties, if we reasonably believe that disclosure of such personal data is necessary, such as to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of website and services; to advance or defend against complaints or legal claims in court, administrative proceedings and elsewhere; or as part of mergers & acquisitions.
THIRD-PARTY LINKS
SpellPunk VR Game might contain links to third-party websites. Once you have been redirected to other websites, any data you provide is subject to said-third party websites’ Privacy Policy.
SECURITY
Personal data is acquired securely and stored in a combination of paper and electronic files to prevent unauthorized access. They are protected by security measures appropriate to the nature of the data. Only trained Incineration Productions employees have access to personal data and abide by our procedures and protocols. However, due to the online nature of the Game, it is important to remember no online data is ever fully protected. There is always a risk the data you transmit to us may be lost to and/or misused by a third-party. By using our Website and Game, you are acknowledging and accepting this unavoidable online risk of data loss and/or misuse.
IN-GAME CHAT, VOICE CHAT, ONLINE FORUMS AND PROFILE
You may choose to disclose information about yourself in our online forums or in-game chat/chatrooms/voice chat (if such a developed) when you play SpellPunk or utilize the Website. Information that you disclose in chat rooms, on the forums is public data, and there is no expectation of privacy or confidentiality in either place. Furthermore, we are not responsible for the information or content you provide or make available in this regard, and you must ensure that your do not disclose information that is obscene, defamatory, or infringing on any rights, including privacy rights, of any third party. Please see our Terms of Use Agreement and End-User License Agreement on this point and for other guidelines.
PROTECTING DATA OBTAINED FROM MINORS
We recognise we have a special obligation to protect personal information obtained from children. We do not and will not knowingly collect personal information from any child under the age of 16. If for any reason we decide to collect personal information of children between 13 and 16 we will ask for their parent or guardian consent. If you are a parent or guardian of such a child and believe that it is using our Game, please contact us at support@incineration.games.
We hereby inform you that before we remove any such information, we may need you to provide proof of identification in order to prevent malicious or accidental removal of account information. If we become aware that a child under the age of 16 is accessing our website, we will delete their information within a reasonable period of time.
YOUR RIGHTS AND ACCESSING INFORMATION
Your EEA Privacy Rights
If you are a resident of the European Economic Area (EEA), which includes all EU member states plus Iceland, Liechtenstein and Norway or a resident of the United Kingdom of Great Britain and Northern Ireland, you have the right to exercise your rights under the EU General Data Protection Regulation with respect to your personal data, which are briefly described below:
· Right to access your personal data: you have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and information.
· Right to rectification of personal data: if you find that personal data that we process about you is inaccurate, you have the right to have us correct such personal data.
· Right to erasure of personal data (right to be forgotten): under certain circumstances, such as if your personal data has been unlawfully processed or you have withdrawn your consent (if the processing of your personal data is based on consent), you have the right to request and obtain erasure of your personal data from us.
· Right to restriction of processing: under certain circumstances, such as if you question the accuracy of your personal data or you have objected to our legitimate purpose to process your personal data, you have the right to request that we restrict the processing of your personal data until a solution has been found.
· Right to object to processing: under certain circumstances, such as if you question our legitimate interest to process your personal data, you have the right to object, on grounds relating to your particular situation, to such processing. In particular you have the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications.
· Right to withdraw consent: if our processing of your personal data is based on your consent, you have the right to withdraw such consent at any time (this will however not affect the processing based on your consent before its withdrawal) by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent..
· Right to data portability: if your personal data is processed by automated means based on your consent or for the fulfilment of our contractual relationship, you have the right to request that we provide you with your personal data on a machine-readable format for transmission to another data controller.
· Right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint regarding our processing of your personal data with your supervisory authority.
Please contact us using the contact details provided below to make a request in respect of your rights. We will use commercially reasonable efforts to respond to your request within 30 days of receiving such request. If we cannot honor your request within the 30-day period, we will let you know the reasons why and when we expect to be able to fulfil your request. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request we will explain why.
Please also note that you can change your contact preferences at any time in your account if you do not wish to receive certain information from us, or if you want to delete your account. You can also exercise this right at any time by contacting us at support@incineration.games on the Website.
Your California Privacy Rights
This section provides additional details about the personal data we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
We do not sell (as such term is defined in the CCPA) the personal data we collect (and will not sell it without providing a right to opt out).
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal data we collect (including how we use and disclose this data), to delete their personal data, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@incineration.games on the Website or at the following address: 31 Layosh Koshut str.,1606 Sofia, Bulgaria. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
CHANGES TO THIS PRIVACY POLICY
Incineration Productions has the right to amend or change this policy from time to time by posting an updated version on our Website. It is your responsibility to check the policy to ensure you accept any new terms. Once we change the Privacy Policy, it will become legally binding 30 days after we post it online. Unfortunately, if you do not agree to those changes (regardless of whether you email us), we must then ask you to cease using our Game..
This policy was last updated on 2020-03-31.
Notwithstanding the general terms of this policy, the collection, use, storage, disclosure, and deletion of personal data may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
CONTACT US
For more information on Incineration Productions and privacy, please contact us at support@incineration.games.
BY USING INCINERATION PRODUCTION’S SPELLPUNK WEBSITE AND GAME, YOU SIGNIFY THAT YOU HAVE READ AND AGREE TO THE CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO OUR POLICIES, PLEASE DO NOT USE OR PLAY THE SPELLPUNK VR GAME.