Privacy Policy

We may amend a list of cookies (specifying the date of such amendment), provided that the current version of the document shall remain unchanged until the scope of amendments in the types of cookies will require to adopt a new version hereof

If we decide to amend this Privacy Policy, we will update this text and the date of its publication and will make a respective notice available within the 4game Service (as defined below). Still, we ask you to drop in from time to time to check the updates.

Please be aware that any and all links to the websites in this Privacy Policy are effective as of the date hereof. We bear no responsibility in the event of their amendment after the date hereof.

Contents

SECTION 1. GENERAL INFORMATION 

SECTION 2. PERSONAL DATA CONTROLLER’S DETAILS 

SECTION 3. CHILDREN’S PRIVACY 

SECTION 4. HOW WE RECEIVE YOUR DATA 

• A.When we receive data from you
• B.When we receive data automatically
• C.When we receive data from third parties

SECTION 5. YOUR DATA WE COLLECT 

• A.Data we may receive from you personally
• B.Data we may receive from you automatically
• C.Data we may receive from other sources (inter alia, automatically)

SECTION 6. BASIS FOR OUR PROCESSING YOUR DATA 

SECTION 7. PURPOSES WE USE YOUR DATA FOR 

SECTION 8. HOW WE MAY SHARE YOUR DATA 

• A.Payment systems
• B.Advertising and tracking partners
• C.Data storage partners
• D.Game developers and right holders
• E.Publicly available information
• F.Anti-cheat and anti-fraud companies
• G.Innova’s analytics partners
• H.Innova’s subsidiaries and affiliates
• I.Change of control
• J.Sharing anonymous data
• K.Additional cases, when we may share information

SECTION 9. HOW LONG WE STORE YOUR PERSONAL DATA 

• A.Compulsory data
• B.Correspondence
• C.Payment data
• D.Device related data
• E.Data collected via cookies
• F.Game related data

SECTION 11. AUTOMATED DECISION-MAKING 

SECTION 12. YOUR RIGHTS CONCERNING OUR PROCESSING OF YOUR PERSONAL DATA 

• A.Right to rectification
• B.Right to erasure (“right to be forgotten”)
• C.Right to object
• D.Right to data portability
• E.Right to lodge a complaint with the supervisory authority

SECTION 13. COOKIES AND TRACKING POLICY 

• A.What are “cookies”?
• B.What types of cookies we use
• C.How long do we store information, submitted via cookies?
• D.Analytical Tools by Google
• E.Google Ads (former Google AdWords)
• F.Google Marketing Platform
• G.Facebook Pixel and Facebook Ads
• H.Yandex Direct and Yandex Metrica
• I.Optimove
• J.INFOBIP
• K.Communication through e-mail
• L.Other third-party technologies
• M.Marketing campaigns optimization 

SECTION 1. GENERAL INFORMATION

This Privacy Policy will tell you, what personal data about you we gather, how we use this information and how you can contact us. In particular, below we will inform you as follows:

• reasons for our processing your personal data;
• what is the purpose of our processing your personal data;
• your rights concerning our processing of your personal data;
• how long we store your personal data;
• whether we transfer your personal data to other recipients and categories thereof;
• whether we transfer (intend to transfer) your data to other countries;
• whether we carry out automated decision-making or profiling.

When we refer to the “4game Service”, we mean the website https://eu.4game.com/, 4game Application, available through the said website, the online games, available at https://eu.4game.com/, our forum, available at: https://4gameforum.com and our other websites and services, that link to this Privacy Policy, irrespective of the manner, you access and/or use them, e.g., whether on a PC or through the tablet/mobile device. Please also be aware that this Privacy Policy is not the only document, which governs your use of the 4game Service, full list of legal documents is available here: https://eu.4game.com/legal/4game. 

This Privacy Policy covers only our activities in respect to your personal data and does not apply to activities of third parties, whom we do not own, control and/or to whom we do not issue mandatory instructions. Therefore, if you wish to disclose your personal data to such third parties, including, in connection with using the 4game Service, please make sure, you have read and understood their policies on personal data processing and you agree with such. Here we also would like to specifically mention, that we bear no responsibility for privacy practices of the third-party websites, that are linked to or from our website. Therefore, once you use the link to quit our website and be redirected to a third-party website, our Privacy Policy will not cover your activities at such third-party website. These provisions also concern your use of third-party software, including, inter alia, software which you installed in accordance with the document “System and Technical Requirements to the User Equipment”, available at: https://eu.4game.com/legal/4game/120. 

If you do not understand, how we process your personal data or wish to make inquiries in accordance with the General Data Protection Regulation (available via the link: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1566480551844&uri=CELEX:32016R0679, hereinafter, the “GDPR”), please contact us using the details in Section 2 below.

SECTION 2. PERSONAL DATA CONTROLLER’S DETAILS

Innova Co. SARL (hereinafter, “Innova”, “we”, “us”) is in the terms of the GDPR the controller of the personal data we process, unless we precisely state otherwise.

In order to contact us on any matters related to this Privacy Policy, other privacy issues, please use any of the below means at your convenience:

• e-mail: privacy@inn.eu
• via post:

Innova Co. SARL

16 RUE ERASME

L-1468 Luxembourg

Should you have any inquiries, related to the 4game Service functioning and/or games therein, please contact our support team here: eu.4gamesupport.com.

SECTION 3. CHILDREN’S PRIVACY

The 4game Service is not directed to children under 13 years and when advertising our services, we do not target children. Use of the 4game Service by children requires prior parental control and permission. We do not knowingly obtain personal information of children under 13 years. 

If you are under 13, please do not use the 4game Service and do not provide any of your information to us, do not create an account with the 4game Service, make purchases with us and/or post any of your information on our resources within the 4game Service. If we reveal, that we have unintentionally received personal data of a child under 13 years we will delete the said data. 

Should you believe, that we collected personal data of children through the 4game Service or the child posted his data within our website without relevant parental consent, please contact us, so that we could promptly delete irrelevant data and take all the necessary steps. However, please be aware that in certain cases such requests may not result in full deletion of respective data (e.g., if another user of the 4game Service reposted such content on third-party resources).

SECTION 4. HOW WE RECEIVE YOUR DATA

Please note, that this Section 4 tells you, how we obtain your data. In Section 5 below you will find further detail on the particular information we collect about you. 

A.When we receive data from you

Major part of the personal data we process we obtain directly from you, when you:

• create an account within the 4game Service and within the online games, available at the 4game Service;
• file a request, inquiry and/or complaint with us;
• wish to participate and/or participate in the online event and/or promotion we organize;
• wish to attend and/or attend an offline event we organize;
• wish to purchase any items and/or services from us and/or add payment information to your account within the 4game Service;
• login to the 4game Service and/or use it;
• contact our support team or approach us otherwise;
• use our forums and/or chats;
• subscribe to our e-newsletters and/or opt in for receiving our marketing/advertising notifications;
• publish any content on our forums and/or official groups within the social networks (vk.com, facebook.com, Twitter) and other online resources (i.e., Twitch, Discord or Youtube channels, etc.).

Your privacy and security of your data are very important for us, this is why we address your attention to the fact that some of our features, through which you provide your data, are automated and/or provide for free text fields, and, therefore, we may not determine, whether you provided us with incorrect or sensitive data. Therefore, we kindly ask you to be careful, when you submit your data and not to share with us any sensitive personal data. If you feel a need to correct or delete your data, please do not hesitate to contact us in accordance with Section 2 and Section 12 hereof.

We want to warn you, that when you use forums and/or chats, information you share therein, may become public or, sometimes used by other persons in the way, you might not be aware of (e.g., he may resend your message to someone else or when you are messaging to someone, who is streaming the gameplay right at that moment). Thus, please pay particular attention to the information you share with others. We also ask you not to share your personal data or the data which may personally identify you, as well as such data on third parties, including, via the 4game Service.

Moreover, the 4game Service may contain links to third-party resources, which Innova does not operate. Although we do our best to provide links only to safe resources, which respect your privacy, we bear no responsibility for approach to content, security and privacy within such third-party resources. Therefore, please familiarize with privacy policies and terms of use available therein.

B.When we receive data automatically

We collect certain information automatically, in particular, when you navigate through the 4game Service and interact therewith (e.g., information on your end user device and its software, on your use of the 4game Service, errors/crashes of the 4game Service, etc.).

C.When we receive data from third parties

In certain cases we can obtain information about you indirectly, including from third parties. This might happen, if any of the below scenarios is in place:

• we receive a complaint from another user of the 4game Service, which refers to you;
• we receive respective information from public authorities, regulators and/or law enforcement bodies (e.g., in the event we receive an inquiry from them, which concerns you, etc.);
• when you link your account within the 4game Service with any social network you have, where such social network may share your information with us based on privacy policy of such social network and privacy settings you chose therein. Please check your privacy settings in respective social networks and, if needed, modify the scope of information on you which they might share;
• when you make payments through third-party payment systems/agents (e.g., when you buy ingame items or pay for subscription via your credit card, we may receive data on your card number and issuer, your billing address and/or other data from the payment system/agent, who processed your payment);
• when we receive advertising and/or analytics from our third-party contractors in order to support our marketing activities, improve the 4game Service, identify your location;
• we receive certain data on you in order to provide you with ingame items or other types of benefits, if you participate in loyalty programs from our partners (e.g., Rostelecom PJSC);
• we may get certain information on your use of the 4game Service and our games and interaction therewith from the cookies and related third-party technologies.

Please note that since our 4game Service provides for free text fields in certain cases and users may approach us via e-mail or other means, we cannot foresee, if you use such features to disclose personal data of some third party. Should you choose to do so, please be advised that you will be treated as an independent data controller in respect to such third-party personal data. Therefore, you should be subject to respective responsibilities and obligations, stipulated by applicable laws, including, inter alia, your obligation to indemnify us against any and all requests, complaints and claims, including those for compensation of damage, caused to third party, whose data you disclosed to us and/or with the use of the 4game Service. Moreover, due to the fact that we do not receive such personal data directly from the ones, to whom it is attributed (but we receive such data indirectly – from you), it is you, who shall obtain consent from such affected third parties prior to any disclosure of their information to us and/or with the use of the 4game Service. In case you have no explicit consent from third parties for disclosure of their information, please make sure, you are fully compliant with other grounds for such use of the personal data, as required under the applicable laws.

SECTION 5. YOUR DATA WE COLLECT

We collect the data on you, as listed below. Please note, that we do not process special categories of personal data (“sensitive data”). Innova does not collect sensitive data in relation to your racial and ethnical origin, biometric data, health data, your political, religious or philosophical beliefs, trade union membership, genetic, health or sex life or sexual orientation, as well as other personal data that is sensitive to fundamental rights and freedoms.

A.Data we may receive from you personally

• your name (name and surname) e-mail address, phone number, date of birth, gender, avatar, photos, ID number (e.g., in the event you approach us for a refund), social network(s), reviews, comments, details on your preferences and interests (depending on the data you indicate when creating and further use of the account within the 4game Service);
• your account data, including your login within the 4game Service, the games you play;
• billing information, payment method and any further details which we may need to process your payments;
• your data, which we receive from you in order to process your inquiries/requests/claims and/or to provide you with support services (such data may vary and may include, for example, your name, the games you play within the 4game Service, the reason why you approach us, devices you use for accessing the 4game Service, purchase details, your account data, data on your ingame characters and progress, the advice we gave you, etc.);
• your data, that you provide in order to participate in our online and/or offline events, workshops, meetings, conferences and/or promotions or loyalty programs (including, inter alia, your name and contact data, your image, information you provide to confirm you are eligible to participate, winner’s data, which is needed to get the prize, data on your use of the promotions or loyalty program, data on your preferences and interests, etc.);
• data you provide when participating in various surveys, polls, questionnaires, etc. (e.g., your preferences, tastes, summary data about you, etc.);
• data on your use of the 4game Service (e.g., account settings, preferences, etc.);
• information you make available when posting on our forums and/or official groups within the social networks (e.g., facebook.com), where such information may include your name, avatar, date of birth, content you posted, commented and/or liked and other information you made available within the forums and/or social networks;
• information you provide to us, when participating in tests we handle;
• feedback you give us, as well as user-generated content, created by you, when using the 4game Service.

B.Data we may receive from you automatically

• information about your device (model and manufacturer of your device, screen resolution, IP address, online identifiers of your devices and applications, domain names of your computer, cookie ID on your browser, your language and territory settings (including wi-fi and IP addresses, which we receive from your device and/or browser), MAC-address of your device, name and version of the operating system, including build version of the operating system, operating system bit count, data on your video (graphics) card, video driver version, video memory size, data on your processor unit, number of processor cores and its clock rate, size of RAM and its clock rate, available disk space, unique device identifiers, etc.);
• information about your connection to the 4game Service (parameters of your network channel, Internet connection, including network bandwidth and delay from User’s computer to servers of Innova, Internet service provider, uniform resource identifier, addresses of resources that you requested on our website, your search requests, time of such requests, methods you used to submit such requests to our servers, dimensions of the file received in response to the request, code that specifies the status of the response to request (success, error, etc.), date and time of your visit, trace route information between your PC and servers of Innova, crash/errors data, response time, browser version and type, date and time of your 4game Service use, information about your activities on 4game Service, such as data on clicks, scrolling, browsing times and other standard server log information, etc.);
• information on your antivirus solution;
• data on the version of 4game Application you are using;
• amount of monetary funds on your account within the 4game Service, your ID in our billing system, payment/transaction/order ID, date and time of payment, amount and currency of payment;
• information about your use of the 4game Service (your games' preferences, progress in our games, playtime, as well as information about device settings, your ingame character activities, logs and data on ingame transactions, log files (information on the actions made by the character in our game generated by the software, fixed in symbolic non-personal form), contents of in-game chats (correspondence), etc.);
• requests that you used when being transferred to our website, webpages, from which you were transferred to our website.

C.Data we may receive from other sources (inter alia, automatically)

• card number and issuer, your billing address, user ID in the payment system, signature of authenticity of the payment, date and time of payment and other data which the payment system/agent may provide us in order to process your payment;
• information, contained in your social network (e.g., facebook.com, etc.), if you connect to the 4game Service therewith (generally, these might include your avatar (profile picture), ID, contact details, location, interests, friends list., etc., depending on the information you filled in within the social network and your privacy settings there);
• analytical and/or statistical data from third parties (e.g., our marketing/advertising partners, analytics partners, etc.);
• data on you, which may be contained in complaint of another user, inquiries of public authorities, regulators and/or law enforcement bodies.

In the light of the above, please be aware that certain payment systems, e.g. PayPal, may also require Innova to provide the following user’s data/the user to provide the following data:

• e-mail of the payer (user);
• payer (user) ID;
• status of the payer (user) confirmed or not);
• name of the payer (user);
• address of the payer (user).

If credit cards are used for payment purposes, the following information may be additionally requested from the user by payment system:

• name of the cardholder;
• masked card number — 6 symbols and last 4 digits;
• country code (if applicable);
• address (if applicable).

Such data is provided by the user directly to the payment systems under the terms of use of such system that the system may require use to enter before processing the payment. Innova does not process such data.

SECTION 6. BASIS FOR OUR PROCESSING YOUR DATA 

We process your data pursuant to the GDPR and other applicable legislation, where the basis for our processing is as follows:

SECTION 7. PURPOSES WE USE YOUR DATA FOR

In particular, we process your data as referred to above (individually and/or combined with other data we receive in accordance with this Privacy Policy) for the following purposes:

• to provide you with the 4game Service upon your request, e.g., so that you can download and run the 4game Application, game client, process payments and use the 4game Service otherwise (e.g., to provide you with the possibility of registration (creation) and operation of 4game account, providing access to the 4game account, formation and performance of the agreement with Innova on using the 4game Service and games, participation in testing of versions/updates of the 4game Service and/or the games, providing game access to you, etc.);
• to contact you in relation to your use of the 4game Service, including, inter alia, on creation and maintenance of your account, your payments, amendments in our policies and legal documents, or when we need to communicate with you about transactions made by you while using our 4game Service or games, as well as when we send to you notifications related to your account security, such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings, etc.;
• your e-mail and/or phone and/or 4game account data, ID and other personal data may be used to identify you and provide you with necessary support (e.g., when we need to communicate with you on your support tickets, on updates of the 4game Service and/or the games available therein, on product patches and fixes, on security issues, etc.);
• get data from you via online Internet forms;
• to handle your claims, requests, inquiries and/or complaints and communicate with you otherwise;
• to ensure your participation in the online or offline events and promotions we organize, including, inter alia, to arrange your receipt of prizes, your travel, etc.;
• if you opted in, - your e-mail and/or phone may be used to provide you with e-newsletters and/or our marketing/advertising notifications, notifications on our upcoming events (unless you unsubscribe);
• to provide you with in-game offers, that you may be interested in;
• to run our business, to improve the 4game Service and servicing our games, to fix bugs, develop new tools, products, to provide you with new features within the 4game Service, including, inter alia, via analyzing polls and questionnaires you fill in, to request your feedback about our 4game Service and games;
• to investigate, handle and prevent improper use of the 4game Service and/or games therein, violations of terms of use of the 4game Service, fraud, cheating, in-game violations - for example, data on organization of game process and information about ingame character activities, logs and data on ingame transactions, game data and commands, the log files, content of in-game chats (correspondence) may be used by Innova for decisions to ban a game account or a character;
• to organize the game process and enhance security, confidentiality and safety of your 4game account and game accounts, e.g. against unauthorized access and disclosure, including resulting from hacking and hacker attacks and/or or fraudulent access, to restore access to your account and/or to the game, restore lost payment made by you, etc.;
• your IP address and other online identifies are used to determine your approximate geographic location, to prevent illegal use of 4game Service and the games, should we have reasonable concerns, that there is a risk to security of Innova’s servers (e.g., blocking of concurrent IP addresses);
• to comply with legal obligations that Innova is subject to (e.g. our obligations to keep certain information under tax laws, etc.);
• for the purposes of the legitimate and legal interests of Innova or a third party (e.g. the interests of our other users), except where such interests are overridden by your prevailing legitimate interests and rights;
• we use cookies and pixel tags to make a link between you and the information you have provided to our website, 4game Service and the game and therefore provide you with personalized content, so that we can give you a better experience, when you return to the website, 4game Service and the game, in order to avoid you from multiple and/or repeated submission of such data in a single visit session or longer, if you wish, which increases the comfort of using websites (unless you disable this feature). Detailed information on cookies is given in Section 13 below;
• we may use your data to create user segment data and create aggregated and anonymous statistics on user’s use of the 4game Service and any elements thereof, our loyalty programs and promotions, which we may share with third parties pursuant hereto;
• to provide you with personalized content, recommendations and advertising, tailored to your needs;
• to process your payments, purchases and refunds, for accrual of bonuses on your account within the 4game Service;
• to combine together personal data that we may obtain from different sources, as mentioned above, inter alia, to create a single or several databases.

We may also use your data for other purposes, not mentioned herein, only based on your prior consent.

Please note, that you can opt-out from receiving our marketing and promotional updates and offers within your 4game account settings or by contacting us, using the details in Section 2 above. 

However, in certain cases we still may send you important information (via e-mails or sms), should these have impact on the 4game Service use (e.g., amendment of involved software, changes in our legal documents, amendments concerning fulfilment of our legal or contractual obligations, etc.). Therefore, your opting-out from receiving our marketing and promotional updates does not affect this type of communications. 

SECTION 8. HOW WE MAY SHARE YOUR DATA

To perform our obligations, we may share your data with the following categories of third parties:

A.Payment systems: 

email address, IP address, information about in-game purchases and other information (e.g., payer (user) ID, status of the payer (user) (confirmed or not), name of the payer (user), address of the payer (user)) you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that you may use for payments and with which Innova may share your data are described at: http://eu.4game.com, our Payment Policy is available at https://eu.4game.com/legal/4game/6.

As mentioned in Section 5(c) above, certain payment systems, e.g. PayPal, may also require Innova to provide the following user’s data/the user to provide the following data:

• e-mail of the payer (user);
• payer (user) ID;
• status of the payer (user) confirmed or not);
• name of the payer (user);
• address of the payer (user).

B. Advertising and tracking partners: 

email, nickname, IP address and other information for targeting, delivery, and measurement of online advertising, or otherwise facilitate transmittal of information that may be useful, relevant, or of interest to you. 

Within the 4game Service we may also use tracking and analytical technologies, provided by our partners, such as AppsFlyer, Ltd. (privacy policy available via the link https://www.appsflyer.com/privacy-policy/) in order to measure performance of our advertising campaigns and their improvement. Please note, that our partners may use APIs and SDKs, implemented in our games and/or 4game Service, so that they could collect and analyze user and device-related data (these may include clicks, installs or other performance indicators or events, which are necessary to evaluate our advertising campaigns).

We also use the Unbounce system, intended for creating landing pages and manage them for the purposes of advertising and promo campaigns, inter alia, for use with paid traffic platforms, such as Google Ads, as well as for evaluating the users’ behavior. Unbounce will act on our behalf as a processor within the meaning of Art. 28 GDPR and will process the data collected on our website exclusively at our instruction. We would like to address your attention to the fact, that your web-browser may interact with the Unbounce system directly and hence Unbounce system may receive data on your IP-address, user ID, date and time, referred URL, etc. and may set cookies on your device, as well as it may collect and store the data you provide via the website. For further details on your personal data processing please refer to: https://unbounce.com/privacy.

Moreover, please be informed that our advertising partners may keep track of events or indicators (such as impressions, clicks, installs, etc.) via their tracking providers in order to measure performance of their advertising campaign. They may use their own third-party tracking providers. For such purposes our advertising partners may use advertising IDs in order to inquire ads effectiveness, as well as informing dormant users of new content within the 4game Service or not showing to a user ads related to the games he already plays or advertising our content to potential users. For these purposes we may share advertising IDs with our advertising partners.

Our partners involved in advertising mailing may include ExpertSender (you can find further details on their privacy policy via this link: https://expertsender.com/privacy-policy/), Optimove (for further details please refer to Section 13(I) below). 

For further details on tracking features, related to our advertising practice, please refer to Section 13 below.

C.Data storage partners: 

some of information is stored using third-party data storage services, e.g. we store most of your responses to our in-game questionnaires using the services of data centers in Luxembourg (Tier 4 data center in Luxembourg). Moreover, we may store certain data we collect from you on servers provided by our cloud service providers. We may provide personal information to our affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any other appropriate confidentiality and security measures;

D.Game developers and right holders: 

we may share non-personally identifiable information publicly and with our partners — like developers or rights holders. This information includes as a minimum your use of the game in question. It may also include your progress in the game, achievements you have completed, your multiplayer game matchmaking information, in-game items and other information needed to analyze, improve and fix game-related issues. We pseudonymize data to reach the only goal of upgrading the 4game Service level; 

E.Publicly available information: 

our websites may also have message boards, forums and/or chats for the users to communicate with each other. When posting a message to a forum or a chat, please note that you are making the respective information publicly available online at your own risk. If your personal information is posted on one of our community forums, you may request us to remove it. If we may not be able to remove your personal information promptly, we will let you know about the reasons;

F.Anti-cheat and anti-fraud companies: 

we may decide to share the information required for our detection, investigation and prevention of cheating, fraud and other prohibited acts in the games with anti-cheat and anti-fraud companies only for the purposes mentioned herein;

G.Innova’s analytics partners: 

Innova uses analytics of its partners such as Yandex.Metrica and Google Analytics (as referred to in Section 13 below) and intelligence and analytics from Microsoft Power BI (please see the Microsoft privacy statement here: https://privacy.microsoft.com/en-gb/privacystatement) in order to provide users with its 4game Service, for the purposes of research and analysis. In this regard we may share encoded user device data with our analytics partners. Please be advised that our analytics partners may assign to the above data a random ID, so that this data will not be matched back to you. Innova may aggregate such data for benchmarking purposes;

H.Innova’s subsidiaries and affiliates: 

as a global company, we collect information that may be processed in our offices worldwide. Your information may also be processed outside of the European Economic Area, e.g. in the Russian Federation, or any other country in which we, our affiliates or subsidiaries maintain presence. Personal data collected is treated confidentially and is used only by Innova or Innova’s affiliate where Innova falls within the category of the controller of personal data and its affiliate – the processor of a part of the personal data. When your personal data is shared with Innova’s affiliates and subsidiaries, Innova guarantees an adequate level of personal data protection, including but not limited to, by concluding standard data protection clauses adopted by the European Commission with Innova’s affiliates and subsidiaries, as well as such third parties;

I.Change of control: 

we may share your data as part of our company’s sale, merger or change in control, or in preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy;

J.Sharing anonymous data: 

we also may share anonymous data (i.e., information which does not directly or indirectly disclose your identity) and aggregated information (meaning information about groups and categories of users, including game statistics and behavior, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the games and 4game Service and they may then share that information with us. Our advertisers may collect this information via tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the 4game Service and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers may also use this information to monitor, improve or modify their operations;

K.Additional cases, when we may share information:

• information about user’s ingame activities, logs and data on ingame transactions, as used for game violations detections (as well as 4game Service violations) in order to prevent or punish for cheating and unfair game, may be disclosed to such user, unless disclosure will compromise the mechanism through which we detect, investigate and prevent such violations;
• without user’s consent the data may be disclosed in cases, required by law, for example, upon the request of the competent authorities, public entities or bodies, our auditors, professional consultants, banks and other competent parties, acting based on the European Union or respective Member State law;
• when we defend and/or enforce our rights (including those of our affiliates) or in the event of litigation between Innova and the user or in case Innova receives request from competent authority. Data on organization of the game process, information about user’s ingame character activities, logs and data on ingame transactions, game data and commands, log files (information on the actions made by the character in the game, generated by the software, fixed in symbolic non-personal form), as well as the content of in-game chats (correspondence) can be combined with the personal information user provides and further disclosed to the court or competent authority;
• should you participate in our events and/or win prizes, in order to arrange your travel and/or prize delivery we may share your necessary contact data with our travel and logistics partners (or instruct you to do so yourself);
• we may use third-party services to fulfill your orders within the 4game Service, to send you e-mails and text messages (SMS), provide you with back-ups.

SECTION 9. HOW LONG WE STORE YOUR PERSONAL DATA

Innova stores data and information during the time periods specified below or until receiving your request to erase personal data, if there is no legitimate reason to keep it longer. Upon expiry of the terms for storing your personal data we will delete it, unless we need to keep certain data due to requirements of applicable laws or during the period this data is necessary for establishment, exercise or defense of legal claims. 

Please be aware that data, that you shared with others (for example, in the in-game chats, via messages or posts on the forum, etc.) may remain visible even after your account is deleted or you clear all respective data from your profile, as we cannot control data, that other users copy when using the 4game Service. Public data in your profile within the 4game Service may still be displayed at third-party services (e.g., people may see it in the search engine results).

A.Compulsory data: 

compulsory data includes e-mail, user location, sex, full name and is stored for the validity period of relevant agreements between user and Innova for use of the 4game Service and respective games, and no longer than 5 years after the termination of such agreements for accounting or tax records, unless there is a legitimate reason for a longer processing.

B.Correspondence: 

Innova keeps records on correspondence with user, including support tickets along with other communications, for the validity period of agreements between you Innova for use of the 4game Service and respective games and 1 year after the termination of such agreements, unless there is a legitimate reason for a longer processing.

С.Payment data: 

The following payment data is stored for 5 years as required by applicable law:

• user ID from Innova’s billing system;
• user ID in the payment system;
• payment (transaction/order) ID;
• date and time of payment (transaction/order);
• amount of payment (transaction/order);
• currency of payment (transaction/order);
• signature of authenticity of the request (payment).

D.Device related data: 

We store the following data, if gathered, no more than for 1 year from the moment agreements between user and Innova for use of the 4game Service and respective games are terminated:

• data on user’s IP address and other online identifiers of his devices and applications;
• browser or device identifiers, browser type;
• operating system, crash data, Internet service provider;
• the date and time of user’s visit, information about user’s activities on 4game services;
• other standard server log information.

E.Data collected via cookies: 

We store information and data submitted by the user on the websites of Innova via authorization cookies (intended to avoid the user from multiple and/or repeated submission of such data in a single visit session or longer, if the user wishes, which increases the comfort of using websites), for no longer than 15 days from the last visit of the user.

Further details on storage time for data, collected via cookies and other tracking technologies, is available in Section 13(С) below.

F.Game related data: 

Innova stores the following data for 1 year from the moment it is collected: data for organization of game process, information about your ingame character activities, logs and data on ingame transactions, game data and commands, log files (information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal form), content of in-game chats (correspondence). If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. 

However, it shall be noted, that if the game account or character was banned based on logs or chat correspondence, such data is stored for 3 years after we reveal the violation unless there is legitimate ground for a longer processing. In case of dispute with the user, log files, chats are stored during the period of the dispute. In the event of litigation between Innova and the user or in case Innova receives request from competent authority, such data can be combined with the personal information user provides and are stored during the period of resolution of the dispute.

SECTION 10. PERSONAL DATA TRANSFERS

Your personal data are stored and processed otherwise using the services of data centers in Luxembourg (Tier 4 data center in Luxembourg). Your information may also be processed outside of the European Economic Area, namely, in the Russian Federation by our affiliate or to the rightholders of the games you played, in accordance with our Privacy Policy. 

Should your personal data be shared with Innova’s affiliates and subsidiaries, Innova guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with Innova’s affiliates and subsidiaries. 

Innova applies necessary safeguards to ensure protection of rights of personal data subjects. In particular, any and all information as sent to us is encrypted (scrambled) via the Secure Socket Layer (SSL) technology. We also implement technical and organizational measures to protect users’ data:

• within Innova we limit access to personal data (i.e., only the personnel, whose access to your data is necessary to run our business, is allowed to access it);
• specific measures for data minimisation to incorporate clear retention periods for personal data;
• using anonymisation or pseudonymisation techniques, other electronic, physical and procedural safeguards, as applicable in the industry;
• ways to allow the data subject to express his or her point of view and contest the decision; and,
• a mechanism for human intervention in data processing.

SECTION 11. AUTOMATED DECISION-MAKING

Please be kindly advised, that as per Article 22 of GDPR we do not make decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

SECTION 12. YOUR RIGHTS CONCERNING OUR PROCESSING OF YOUR PERSONAL DATA
 

Please be advised, that in order to exercise your rights, stipulated in this paragraph, you can approach Innova using the below contact details: 

Innova Co. SARL

16 RUE ERASME

L-1468 Luxembourg

e-mail: privacy@inn.eu

You have the following options in respect to your data, that we process:

• Opt-out of Innova processing your information: you are entitled to withdraw the consent, you gave us to process your data;
• Delete your personal data: you can file a request with us to delete all or certain part of information about you, that we process;
• Access your data: you are entitled to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided;
• Correct and amend your data: please feel free to contact us, should you discover, that your data is inaccurate or incomplete;
• Object, limit or prohibit our use of your data: you can approach us with a request to fully or partially stop using your data or limit such use.

Please find below further details on your rights:

A.Right to rectification 

It is you who should control, which particular login, contact details (including e-mail and phone number), payment methods, accounts in social networks we associate with your account within the 4game Service. In case of processing personal data, we shall endeavor to ensure by implementing measures to keep it accurate and up-to-date for the purposes for which it was collected. In case your personal data is inaccurate or incomplete, you can change the information you provided either yourself (directly within the 4game Service) or by contacting Innova via details indicated in this Section 12. 

B.Right to erasure (“right to be forgotten”) 

You have the right to request a deletion of your personal data by requesting for account deleting via the details listed above. Deleting your account will lead to loss of access to the 4game Service and games, available therein, through such account, you will also lose the account and game-related information, which is linked to your account within the 4game Service, including, inter alia, payment information.

Please be advised that you can obtain from us the erasure of your personal data without undue delay, where one of the following grounds applies (unless processing is necessary pursuant to Article 17(3) of GDPR, when the below provisions shall not apply to the extent that processing is necessary):

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;
• you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Innova as the controller is subject;
• the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of GDPR.

In some cases, considering the complexity and number of the requests, the period for personal data erasure may be extended, but for no longer than two further months.

C.Right to object

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to this processing in accordance with Article 21 of the GDPR. If you object we will no longer process your personal data and you will lose the access to 4game Service and games through your account, unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. 

D.Right to data portability 

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us. In exercising your right to data portability pursuant hereto, you are entitled to have the personal data transmitted directly from us to another controller, where technically feasible. Please be aware that exercise of the right to data portability shall be without prejudice to right to erasure (right to be forgotten). Moreover, your right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest, as well as such right shall not adversely affect the rights and freedoms of others.

E.Right to lodge a complaint with the supervisory authority

Should you have any complaints about our compliance with this Privacy Policy and/or applicable legislation, please do not hesitate to contact us. We will carry out all the necessary checks and will do our best to resolve the dispute timely and in accordance with relevant regulations.

Pursuant to Article 77 of GDPR, without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes GDPR.

Please be kindly advised that according to the laws of the Luxembourg (as the country where Innova as the controller is incorporated), effective as of the date of this Privacy Policy publication, it is National Data Protection Commission (Commission Nationale pour le Protection des Données, the “CNPD”), which acts as the data protection supervisory authority. Please use the following contact details, should you desire to approach the CNPD:

Commission nationale pour la protection des données

Service des réclamations

1, avenue du Rock’n’Roll

L-4361 Esch-sur-Alzette

Tel.: (+352) 26 10 60-1

website: https://cnpd.public.lu/en.html (details for lodging complaints can be found, inter alia, via this link: https://cnpd.public.lu/en/support/protection-des-donnees.html#reclamations).

SECTION 13. COOKIES AND TRACKING POLICY

We use cookies technology within our 4game Service and in our e-mail communications with you as outlined in this Privacy Policy. 

A.What are “cookies”?

Cookies are small pieces of information stored by your internet browser on your computer’s hard drive. Like most website providers, Innova uses cookies to make a link between you and the information you have provided to the 4game Service and therefore provide you with content tailored to your needs. For example, use of the cookies technology enables us to understand, which users clicked on which elements of our website and afterwards we can show such users desirable content. To put that in context, each time you visit our website, your Internet browser will send us back the cookies, that are stored by your internet browser on your computer’s hard drive, so that we can customize your experience within the 4game Service to offer you personalized content or just facilitate the sign-in process for you. In order to benefit from such features, you should accept and enable the use of cookies in your browser. Cookies are often used in combination with pixel tags. A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. 

Please be aware that third parties may also collect personal data about your online activities during certain period of time and within different websites, including, when you visit our websites.

If you choose not to accept cookies you may not be able to fully use all of the functions and benefits of the 4game Service. For example, if you block or erase cookies, we will not be able to remember your settings and preferences, we will not be able to provide you personalized content either. By activating the cookies feature of your browser you agree and consent to the data collection and processing as explained herein. At the same time, majority of Internet browsers will enable you to delete cookies from your computer’s hard drive, refuse acceptance of cookies and/or receive a specific warning before cookie is stored within your system. Further reading about cookies is available here: www.aboutcookies.org.

Below please find links to instructions, how to manage cookies on popular browsers:

• Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
• Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Microsoft Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
• Opera: https://www.opera.com/help/tutorials/security/privacy/
• Apple Safari: https://support.apple.com/en-gb/safari

To discover date relating to other browsers, please visit such browser developer's website.

Please note that the below list of cookies is effective as of the date hereof and may change from time to time. However, all the cookies have the same designation as mentioned below and, therefore, amendment of the cookies list shall not adversely affect you.

B.What types of cookies we use 

• necessary cookies: these cookies make our website work and enable us to carry out transmission of a communication and ensure core functionality of our website, such as providing secure log-in. For instance, with the help of these cookies we will remember your log-in details and will provide you with secure log-in; we also will be able to remember your transaction or other tasks in progress. Necessary cookies are automatically enabled when you use our website. With the help of these cookies you can enjoy full functionality of our website, where without the use of cookies such functionality may be unavailable. Therefore, you cannot opt-out from the necessary cookies and no consent from the user is required for these cookies.
• functional cookies: cookies of this type are intended to provide us with technical information on your use of our website (these may include, inter alia, data on parts of our website you visited, whether you clicked certain parts of e-mail communication from us, etc.). Therefore, such cookies enable additional functionality like saving preferences such as allowing social interactions, allowing you to post comments on our website, and analyzing usage for our website optimization. We may use functional cookies to detect and evaluate errors, which occur during our websites use, estimate the number of responses (clicks) to our advertising, analyze performance of our website, advertising and e-mails, to remember, what is stored in your shopping cart. All of these if important for us to manage performance of the 4game Service and to timely improve it. These cookies are optional for our website use and require your consent, but they do make it more convenient;
• analytical cookies: we may use Google Analytics and/or other analytical technologies, which uses cookies, or other analytical cookies, in order to improve our website via collecting and reporting information on your use of our website. These cookies are optional for our website use and require your consent, but they do make it more convenient. For more details please refer to Section 13 (d) below;
• tracking and referral cookies: we use tracking cookies to ensure more efficient functioning of our website. Referral cookies are sent to your devices not by us, but by our business partners and help us to understand, when our business partners refer you to our website and whether your visit results in use of the 4game Service and making purchases from us. We may disclose such information to our respective business partners, but only in an anonymous form, so that you will not be directly identified. We also use tracking cookies of our partners and our own tracking cookies, which help us to understand users’ behavior within our 4game Service and websites in order to make our advertising campaigns more effective and improve interaction between the user and our 4game Service and websites. These tracking and referral cookies are optional for our website use and require your consent, but they do make it more convenient;
• advertising cookies: cookies of this type help us to provide you with advertising, which is more relevant for your needs, and estimate results of such advertising. Advertising cookies collect information to find out your interests, provide you advertising, based on your interests and tailored content, facilitate analytics and improve our 4game Service. In order to do so these cookies day collect data on your using our website (e.g., which services you clicked on), where such data may be further used, when you re-visit our website or websites of our advertising partners. As a result of using advertising (targeting) cookies we can personalize marketing e-mails we send to you of offers we show you, our advertising partners may show you advertising of our products and services on other websites, allow you to share pages with social networks, etc. Please note, that data, collected by such type of cookies, can be accessed and used by us and our affiliates, as well as by our advertising partners. These cookies are optional for our website use and require your consent, but they do make it more convenient;
• third-party cookies: when you use our website and it contains certain content, as displayed from a third-party website, you may receive cookies from such third parties. Please note that your personal data will not be collected and stored by these cookies, unless you log-in to your account within the 4game Service. You may receive such cookies from YouTube, Facebook, Yandex, VKontakte, as referred to below. However, please be aware that Innova does not control collection and use of such cookies and has no access to the data, obtained therewith. We ask you to carefully review privacy policies and cookies regulations of such third parties to be aware, how they collect and process your data.

C.How long do we store information, submitted via cookies?

We store information and data submitted by you within the 4game Service via authorization cookies (intended to avoid the user from multiple and/or repeated submission of such data in a single visit session or longer, if the user wishes, which increases the comfort of using websites), for no longer than 14 days from the last visit of the user.

Moreover, Innova uses temporary cookies (cookies files are deleted once the user closes browser) and permanent cookies (cookies files stay in the memory of the user’s PC until either the user deletes them or their storage period expires) as follows:

Updated on 10 November 2022
 

Innova may also use the following third-party cookies on Innova’s websites:

 D.Analytical Tools by Google 

We use Google Analytics provided by Google, LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043 USA ("Google"). 

We use remarketing audiences in Google Analytics, which enables us to re-engage audiences that are likely to convert (please refer for further details on this tool here: https://support.google.com/analytics/answer/2611268?hl=en). 

Google Analytics is intended for web analysis, i.e., gathering, collection and analysis of data about the behavior of websites visitors. For example, through Google Analytics there may be collected data on website, from which the particular user comes from (so-called referrers), which subpages of the website the user accessed or how often and for which period of time the user viewed a subpage. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google might transfer the personal information collected via this technical procedure to third parties. For more information about Google Analytics cookies use, please refer to https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. You can prevent the collection of data about your use of the website (including your IP address) generated by the cookie, and the processing of data by Google, by accessing Google Analytics opt-out browser add-on through the following link: http://tools.google.com/dlpage/gaoptout?hl=en. 

This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics.

In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs. 

As IP anonymization is activated on our website, your IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and to provide further services related to website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.

In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data. 

In order to ensure compliance with the GDPR, we also entered into the Google Ads Data Processing Terms with Google being the data processor. 

Our website also uses Google Analytics performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com.

We also use Google Tag Manager as a tag management solution in order to manage our website tags without editing code. Further details on the features of Google Tag Manager are available at: https://marketingplatform.google.com/about/tag-manager/features/ 

Further details on how Google uses information from sites or apps, that use Google services are available at: https://policies.google.com/technologies/partner-sites. Data on Google Analytics’ data practices are available via the link: https://support.google.com/analytics/answer/6004245?hl=en.

Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/. The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/. Additional information on cookies use by Google is available via this link: https://policies.google.com/technologies/types?hl=en&gl=GG. 

E.Google Ads (former Google AdWords) 

We use the Google Ads features, provided by Google. Innova and Google may use both first-party cookies and third-party cookies together in order to improve our website and provide you with ads based on your previous visits to our website. For example, we may advertise to those visitors of our website, who have not completed some task on our website during their last visit (e.g., started to use the contact form or initiated a purchase). In such case we may address such users by showing our ads within the Google search engine results or within the Google Display Network. Moreover, third party vendors, including Google, may serve you with ads, based on your visit of our website, on other websites.

Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en. You can opt out of Google’s use of cookies or device identifiers by visiting the Google’s Ads Settings via the link https://adssettings.google.com/authenticated. Alternatively, you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page (available at: http://www.networkadvertising.org/managing/opt_out.asp) or control the use of your Android or iOs device identifiers by using your device’s settings (more information from Google is available here: https://support.google.com/ads/answer/1660762#mob). 

F.Google Marketing Platform

We use the online marketing tools of Google Marketing Platform offered by Google (description is available at: https://marketingplatform.google.com/about/). Google Marketing Platform uses cookies, so that it can activate advertising, that is relevant for a particular user, improve marketing campaign results or release the user from repeated display of the same ads. Google Marketing Platform may also use cookies IDs in order to track conversions as per ads requests (i.e., when the user, after seeing ads via Google Marketing Platform tools, visits the website of such advertiser, using the same web browser, and makes a purchase there). 

We also use Display & Video 360 by Google, which offers a single tool for planning campaigns, designing and managing creative, organizing and applying audience data, finding and buying inventory, and measuring and optimizing campaigns. Further details on this tool are available here: https://marketingplatform.google.com/about/display-video-360/.  

Please be aware, that use of the above Google tools may imply automatic establishment of direct connection between your web browser and the Google servers. This means, that Innova does not control or influence the scope and use of your data, as collected by Google. Please note that in this context data processing outside the European Union/the European Economic Area may occur. Google has accepted the provisions of the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.

In this respect please be aware, that through the its tools Google may receive data on the fact, that you visited certain parts of our website and clicked on respective ads. If you do so being logged-in in your Google account (e.g., at https://mail.google.com), Google may also associate your use of our website with your Google account. However, if you have not logged-in in your Google account (or you don’t even have such), it may be the case that the provider may get data on your IP address and store such data.

In order to prevent use of your data as specified above, you may prohibit third-party cookies in your browser and delete them from your computer, as referred to in Section 13(A) above. Additionally, you can turn off ads personalization through Google website: http://www.google.com/settings/ads. 

Further information about Google tools is available within the Google resources: https://marketingplatform.google.com/about/, https://policies.google.com/technologies/ads. Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en. Additional information on cookies use by Google is available via this link: https://policies.google.com/technologies/types?hl=en&gl=GG. 

G.Facebook Pixel and Facebook Ads

We use Facebook pixel, which is an analytical tool, offered by Facebook Inc. (1 Hacker Way, Menlo Park, CA 94025, USA) and Facebook Ireland Limited (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) (hereinafter jointly referred to as the “Facebook”) that allows us to measure the effectiveness of your advertising by understanding the actions people take on your website. It works by loading a small library of functions which we can use whenever a site visitor takes an action that we want to track. 

The data collected via Facebook pixel is anonymous to us, which means that we do not see the personal data of individual users. Please be aware, that Facebook stores and processes such data. Moreover, Facebook may link the above information to your Facebook account, as well as use it for its own marketing activities. For further details on processing personal data by Facebook please refer to their Data Policy, which is available at: https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. Also both first- and third-party cookies may be used with Facebook pixel. Facebook Ads, including Facebook cookies, help us to evaluate, optimize and carry out formation of the audience for the purposes of such advertising campaigns within Facebook or its other advertising platforms, including Instagram. This service also helps us to better understand users’ behavior when visiting our 4game Service, our websites and/or Facebook pages, as well as to ensure display of our advertisement to the users, who are most likely to be interested in our 4game Service. For this purpose we analyze which content a user has viewed and interacted with on our website.

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook Ads by contacting the following address: https://www.facebook.com/settings?tab=ads.

Facebook has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

H.Yandex Direct and Yandex Metrica

Our website uses the Yandex Direct, a one-stop platform for posting contextual and display advertising that allows us to build a sales funnel and solve marketing tasks at all levels, as offered by Yandex Europe AG, and Yandex.Metrica web analytics service, as provided by the Yandex Oy Limited Company - Moreenikatu 6, 04600 Mantsala, Finland (hereinafter Yandex Europe AG and Yandex Oy Limited Company jointly referred to as “Yandex”). 

Yandex.Metrica uses “cookies,” small text files placed on users’ computers to analyze user activity.

Information collected by cookies does not reveal your identity, but it can help us to improve our website performance. Information about your use of this website collected by cookies will be transferred to Yandex and stored on Yandex’s server in the EU and the Russian Federation. Yandex will process this information to assess how you use the website, compile reports for us on our website operation, and provide other services. Yandex processes this information as specified in the Terms of Use of Yandex.Metrica Service.

You can opt out of using cookie files by choosing the corresponding settings in your browser. You can also use the tool https://yandex.com/support/metrika/general/opt-out.html. However, it can affect some website functions. By using this website, you agree that Yandex can process your data in the above manner and for the above purposes.

For further details please refer to the Yandex Privacy Policy, available at: https://yandex.com/legal/confidential/. 

I.Optimove

We use Optimove, a service provided by Mobius Solutions, Ltd. and its affiliates (hereinafter referred to as the “Optimove”), for marketing campaign personalization, which analyzes data concerning or provided by our users and recommends certain marketing actions. Optimove helps us to determine target audience for our advertising and marketing activities, as well as facilitates our engagement with users of social networks and analysing of responses to our e-mail communications.

We also use Optimail, which is Optimove’s native email personalization and delivery platform, powering all aspects of preparing, delivering and tracking hyper-personalized email marketing campaigns. Seamlessly integrated within Optimove, Optimail offers us an email platform, which is designed for personalized customer marketing.

You can find further details on the Optimove privacy practices via the link: https://www.optimove.com/privacy-policy. 

J.INFOBIP

We also use a global cloud communications platform by INFOBIP LIMITED (INFOBIP), which enables us with the possibility to build connected user experiences across all stages of the user journey at scale, with interactions over users’ preferred channels. We use INFOBIP platform, inter alia, to send SMS, track messaging history, etc. INFOBIP privacy notice is available at: https://www.infobip.com/policies/privacy, further information on data protection is available at: https://www.infobip.com/policies/processors.

K.Communication through e-mail

Please be aware, that when sending you e-mails, we may use tracking technologies in order to understand, whether you clicked on, opened or forwarded e-mail, we sent you. Should this approach bother you, please unsubscribe from our marketing e-mails, since we cannot disable tracking technology separately. You can unsubscribe from marketing communication by contacting us (please use our contact details in Section 2), otherwise you may follow unsubscribing instructions in the respective e-mails, you receive from us, or unsubscribe yourself via unticking respective boxes in the “mailings and notification” settings of your account within the 4game Service.

L.Other third-party technologies

Innova may also use local storage technology of the following partner networks: Youtube, Facebook and Twitter. You can find further details on data privacy policies via the following links: for Youtube: https://policies.google.com/privacy?hl=en, for Facebook: https://www.facebook.com/about/privacy/, for Twitter: https://twitter.com/en/privacy.

M.Marketing campaigns optimization

We use the service of third-party companies, such as Kool Things Sp. z o.o., for marketing campaigns optimizitation and for the search of the new alike auditory. We may share the following data: e-mails, IP address, profile ID in social network (like Facebook), browser version, Google tracking data. The data may be mixed in different order to meet our marketing targets. You can find further details on data privacy policies via the following link: https://koolthings.com/privacy-policy/