This Policy applies to all official websites of Innova, where it is placed (published) and through which you get access to our services and Games (eu.4game.com and its subdomains). This Policy is based on the principles set forth the Regulation (EU) 2016/679 of April 27, 2016 (General Data Protection Regulation) coming into force from May 25, 2018 (hereinafter the “GDPR”).
Personal data - any information that can either itself identify you as an individual or that can be connected to you indirectly by linking it to personally identifying information.
Controller in the sense of the GDPR and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding services and Games is Innova Co. SARL (referred as “Innova”), which details are specified in Contacts.
This document covers the full scope of purposes and reasons for collecting and processing of Personal Data, determines and limits what Personal data we collect and how we use it (several sections below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User (Contacts section).
Purposes of processing of Personal data
Innova collects and processes your Personal Data in order to perform the agreement concluded between you and Innova and according to Article 6(1) (b) of the GDPR. Innova processes Personal Data for the following purposes:
• for the performance of Innova’s obligations under the contract you have entered into;
• for enhancing the security and safety of your 4game and game accounts;
• to communicate with you about transactions made by you while using our services or Games, as well as to send you notifications related to your Account security such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings and similar;
• to send you an information about updates in our services or Games, about features on our sites, about upcoming events (online and offline) and other information related to our services or Games (in case you have not unsubscribed);
• to inform you about changes in our policies and legal documents;
• to communicate with you in order to resolve any problem you faced while using our services or Games;
• to inform about our activities (in case you have not unsubscribed); for developing new tools, products or services for your;
• to provide support, as well as technical support, including, but not limited to, Game and 4game services updates, product patches and fixes and other similar communications;
• for compliance with legal obligations that Innova is subject to (e.g. our obligations to keep certain information under tax laws);
• for the purposes of the legitimate and legal interests of Innova or a third party (e.g. the interests of our other customers), except where such interests are overridden by your prevailing legitimate interests and rights;
• to communicate with you when you take part in online or offline competitions, events or game tournaments organized or supported by Innova;
• to arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning in online or offline competitions or events, etc;
• to improve Innova’s services and Games, as well as while requesting your feedback about our services and Games.
The scope and purpose of processing of your Personal data, among other conditions for the processing, is specified in this Policy. We will notify you about any significant changes in our Policy and ensure your consent .
Innova does not collect sensitive data in relation to Users’ racial and ethnical origin, biometric data, health data, their political, religious or philosophical beliefs, trade union membership, genetic, health or sex life among other personal data that is sensitive to fundamental rights and freedoms. You should be aware that if you at your own discretion post (publish) your Personal data on forums, game chats or groups in social network related to Innova’s services or the Games or use them as your login or as character’s names (disclose), your data become available and known to the public and you become solely responsible for the consequences of such disclosure.
Innova does not enter into a contract or collect data of persons under the age of 18. 16 –years old persons (in case it’s below of their legal age of full legal capacity in their country of residence) may enter into a contract with Innova only through consent of their legal representatives (parents, adoptive parents or guardians). Such legal representatives also agree to the processing of User’s Personal data including their and the persons’ represented by them. In case Innova does not provide the procedure, it has right to refuse in access for such users. At any time Innova may contact with the User and request contact details of legal representatives and/or their consent mentioned above. Innova encourages parents to instruct their children not to give out personal information when online.
Where applicable, all User’s rights and obligations to this Policy are exercised exclusively through their legal representatives.
This document covers the full scope of the reasons for collecting and processing Personal Data, determines and limits what Personal data we collect and how we use it, how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User (Contacts section).
Personal data and information processed for purposes of performance of the agreement
Innova collects and processes your Personal data for the purposes related to providing to Users services and Games, namely: registration (creation) and operation of 4game account,, providing access to the 4game account, formation and performance of the agreement with Innova on using 4game Service and Games, providing the Game, game services and game access to Users, sending, processing of and responding to support tickets along with other communications with Innova, payment acceptance, improve 4game Service and Games etc.For these purposes Innova requires and collects the following Personal data (referred as “Compulsory Data”):
- Obligatory data, such as:
• User’s ID in social network that is used for registration at 4game (if applicable)
• place of User’s residence (location) and
- Additional data that may be additionally collected by Innova for execution of the agreement made with Users related to the use of 4game Service and the Game, such as:
• cell phone number
• full name
• date of birth
• partial number of User’s ID
Compulsory Data is required for Innova to provide services and the Game to Users and perform other obligations under the agreements concluded with Users. Request for erase of such data may result in your inability of using Innova’s services as set forth in below.
Compulsory Data may be collected through, namely:
• through registration with 4game service and/or with the Game;
• while contacting Innova via e-mail, fax, phone or mailing address of Innova;
• while contacting the support team or Innova otherwise;
• while using forum, chats related to 4game service and/or the Game;
• while using 4game Service and/or the Game otherwise (including information you provide to when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details);
The Additional data is not obligatory to provide by Users to Innova, is collected and saved for using certain Games. Innova will inform you about it in the appropriate agreement regarding the Game.
Such Additional data may also be collected to ensure security and confidentiality of your account, e.g. against unauthorized access and disclosure, including resulting from hacking and hacker attacks and/or or fraudulent access, to restore access to the User’s account, restore lost payment made by the User or for other purposes to provide services and the Game to Users. Innova will inform you about it through 4game service, the Game or other means of communication.
You may also freely provide Additional data to Innova without its request upon your discretion and consent. Such data will be processed according to this Policy.
Innova may also collect non-personal information of Users and store it separately from the Personal data as described below in the Policy. Such non-personal information can be connected to Personal data in case set forth in this Policy. We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Anonymous data, aggregated or not, may be shared with third parties.
Be also aware, that for the purpose of organization of game process Innova collects information about your ingame activities, logs and data on ingame transactions. Such data also used for Game violations detections (as well as 4game platform violations) in order to prevent or punish for cheating and unfair game. This data is used for the purposes of detection, investigation, prevention and, where applicable, and stored only for the minimum amount of time needed for this purpose. 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. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations. Also be aware that enjoying user’s rights shall be in balance with rights and interests of other users, as well as lead to balance and should not affect the rights and freedoms of other parties, including trade secrets or intellectual property.
Innova may request personal information from you in paper form or in the support program. Providing this information by e-mail is not desirable, because it cannot guarantee the security and confidentiality of the data. The decision on method of providing the data is left for your discretion.
Processing and storage
Compulsory data is stored for the validity period of relevant agreements with Innova, 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.
Innova keeps records on correspondence with User, including support tickets along with other communications, for statistics purposes, to deliver, develop and improve 4 game Service and the Game, , to support Users in using the services and the Game, to ensure security and confidentiality of the User’s account and data, to restore access to the User’s account, services and/or to the Game, to restore lost payments made by the User etc.
Such information is stored for the validity period of relevant agreements with Innova and 1 year after the termination of such agreements, including the User Agreement, unless there is a legitimate reason for a longer processing.
Anonymous data and non-personal information of Users are kept separately from Personal data and stored for no longer than the validity period of relevant agreements with Innova.
Payment data collection for purposes of using fee-based Games and 4game Service
When the User tops up his or her 4game account or make payments via payment systems (payment agents such as Paypal and Scrill) available through 4game service at eu.4game.com, Innova and the payment system (payment agents) that is chosen by the User to process the payment exchange with the following Payment Data:
• 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)
Payment Data is stored for 5 years as required under applicable law.
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).
Collection of data for participation in promotion (marketing or advertising event)
Innova may use your Personal data, including e-mail and/or phone number, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about services of Innova and its affiliates and the Game. If you do not wish to receive such information, you can unsubscribe from receipt of such information following the instructions as described in the corresponding messages or via 4game account interface.
Collection of data for service notification
Innova may use your e-mail and/or phone for sending notifications or other notifications, for example, in case of communication within the scope of support tickets, response to your requests or other communications related to access to Innova’s services and/or the Games, password restoring or otherwise restoring access to the User’s account.
You can disable this feature at any time, though you will be unable to use such features, including being informed on a login to your account.
Collection of non-personal data for game service provision and for improvement and development purposes
In order to provide quality services and to justify your expectations of Innova’s services and/or Games, Innova collects anonymous data:
• name and version of the operating system,
• the size of RAM
• the size of available disk space
• parameters of the network channel and internet connection such as network bandwidth and delay from User’s computer to servers of Innova, trace route information between your PC and servers of Innova, etc.
• other data that is mentioned in the Technical requirements to the Game
Innova collects information about your games' preferences, progress in Games, playtime, as well as information about device settings, unique device identifiers, and crash data. Innova processes and stores such data also to evaluate development plans, provide updates to the services and Games, bug-fixing.
Such information is stored for the validity period of relevant agreements with Innova and 1 year after the termination of such agreements, unless there is a legitimate reason for a longer processing.
IP (internet protocol) address
When you visit websites, use services of Innova and/or the Game, Innova may gather and store the information about your IP address and other online identifiers of User’s devices and applications to determine your approximate geographic location. By using such identifiers Innova provides you with information, services and the Games available at or intended for the territory where you are.
Also, information about the IP address and other online identifies is used to prevent illegal use of Innova’s services and the Games if there is reason to believe that there is a risk to security of Innova’s servers (i.e. blocking of concurrent IP addresses).
Innova also collect a browser or device identifiers, browser type, operating system, crash data, Internet service provider, the date and time of your visit, information about your activities on 4game Services and other standard server log information.
The data on the IP address and other online identified is stored no more than for 1 year from the moment of the agreement termination.
Innova would like to draw your attention that if you choose not to accept cookies you will not be able to fully use all of the functions and benefits of our website and the 4game. By activating the cookies feature of your browser you agree and consent to the data collection and processing as explained herein.
Innova also uses so-called authorization cookies, which are intended to store information and data submitted by the User on the websites of Innova, 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. Such data are stored for no longer than 15 days from the last visit of the User.
We use Google Analytics provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on visitors' computers, to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on its servers.
IP anonymization has been activated. Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout?hl=en
Collection of data on using rights to Games
Innova collects data for organization of game process and collects information about your ingame character activities, logs and data on ingame transactions. We also collect Game data and commands the so-called 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). This data may be used by Innova for decisions to ban a Game account or user’s character, according to the rules of the relevant Game.
Such data are not Personal data and stored for 1 year from the moment it is collected.
If Game account or character was banned based on logs or chat correspondence, such data is stored for 3 years after the violation unless there is legitimate ground for a longer processing.
In case if 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 you provide and are stored during the period of resolution of the dispute.
Innova’s endeavors to implement technical and organizational measures to protect your personal data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure or access. Innova, affiliates and third parties authorized to access the personal data are required to give an undertaking to maintain such confidentiality and secrecy.
Among other measures, any information sent to us is encrypted (scrambled) using Secure Socket Layer (SSL) technology. This is industry standard encryption technology that protects your data whilst being sent over the Internet from being intercepted and misused by third parties.
Innova has put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security, and correctly use the information collected.
Sharing of User’s information
Innova does not transfer your data to anyone, except for those specified in this Policy or as provided by the GDPR, and this may be related to the provision of our services and performance of contracts you have concluded with Innova. If such transfer to third parties is related to any other purpose we will ask for your explicit consent to such transfer.
Innova does not sell your personal information and does not receive benefits from any treatment of your data. Innova does not use your data for advertising or promotion of products and services of third parties, other than those listed here.
Chasing a goal of performing of its obligations, Innova may share your data with the following categories of third parties:
Payment systems: email address, IP address, information about in-game purchases and other information you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User for payments and with which Innova may share your data are described at: http://eu.4game.com.
Advertising 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.
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 ownership 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 service level.
Publicly available information: our Sites may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums, please use inform us with request to its removal. If we may not be able to remove your personal information promptly, we will let you know about the reasons.
Anti-cheat and anti-fraud companies: we may decide to share the information required for our detection, investigation and prevention of cheating in the Games and violations of agreements related to the Games only for the purposes of detection, investigation and prevention of cheating in the Games.
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.
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 entering into standard data protection clauses adopted by the European Commission with Innova’s affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the standard data protection clauses upon your request.
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 behaviour, 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 through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services 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 will also use this information to monitor, improve or modify their operations.
Innova stores data and information during the time periods specified in this Policy or until receiving your request to erase personal data, if there is no legitimate reason to keep it longer.
Personal data cannot be erased or anonymized when it is necessary to comply with law. If you wish to change and/or erase your personal data you can submit such request to Innova’s specialists on personal data to do this using the details in the Contact section below. Please be aware that if you have valid agreements on using 4game, Innova’s services and/or the Games and submit the request on erase and/or anonymization of your personal data, you may lose the ability to use the services of Innova and the Game from the date when your request is completed.
When your data is incorrect or inaccurate you must either amend it on your own or ask Innova’s specialists on personal data to do this using the details in the Contact section below.
If Innova finds that you provided incorrect or inaccurate personal data, it may restrict (ban) your Game account until you amend it.
Payment data cannot be changed and/or erased at your request unless you provide Innova with the documented prove of necessity to make such changes.
Innova does not erase the data if any violation or abuse has been occurred by Users or Innova has been summoned not to erase the data at competent authority’s request or a court order. If a User requests the erase of the personal data, while a prior request (s) from that User is still being processed, such data can be erased only when the User has recalled/cancelled all previous requests.
Innova stores the log files within the periods specified in section “Collection of data using rights to the Games”.
The data is stored separately. Your data may be combined with other data collected by Innova in exceptional cases, for example, in case of a violation by users of the agreement with Innova, the rules of the game, the availability of a dispute between Innova and the user, conduct of financial control and accounting, etc. As for the detecting violations, be aware that Innova uses anti-cheating tools that collect info about the processes in use while you are accessing Games.
The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having the access to his private account. All changes are logged.
Disclosure of information
You are required to provide only correct and accurate information and data belonging to you.
You have the opportunity at any time:
• to contact Innova on the issues relating to the processing of your personal data, issues related to this Policy;
• to obtain information about what your personal data and for what purpose is processed by Innova, and whether they were disclosed (within the period of preceding two years)
using the details of Innova’s specialists on personal data in the Contact section below.
The requested information is provided to you in electronic form. Its provision on another data medium is possible at the sole discretion of Innova or in cases when such obligation is required by the applicable law.
This information is provided upon your request sent as specified in the Contact section. You will receive a reply within a period not exceeding 30-day period.
The data collected will be treated confidentially and 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. Innova guaranties that the processor complies with the GDPR, this Policy and ensure the adequate level of protection of such Personal data. The processor shall only be entitled to use Personal data for the purposes of providing services to Users and the rights to use the Game among other related purposes or transactions on behalf of Innova.
Your data are stored on Innova’s servers in Tier 4 data centre in Luxembourg. If Innova makes a decision to store the data outside the EU we will strictly follow the legal requirements of the applicable law including getting necessary approvals and authorizations. Depersonalized data that cannot anyhow identify the User can be transmitted to the right holder of the Game ((Rightholder of particular Game specified in the agreement to the Game).
This Policy and the collected data shall be binding upon and shall inure to the benefit of Innova’s successors and assigns (for example, in case of merger/incorporation, transfer of rights to provide service under the license, etc.). The processing may be also performed by Innova affiliates.
Without your consent the data may be disclosed in cases required by law, for example, upon the request of the competent authorities.
We particularly draw your attention to the fact that Innova will never ask you to provide your personal information in the way it becomes public, such as forums and chat rooms, which may accompany the provision of Innova’s services, or in the name of the game character or in the selection of username.
Once you disclose your Personal data, including posting them on forums and chat rooms or using your Personal data as name of game character, you should be aware that this data is publicly available and can be used by third parties, and Innova ceases to be responsible for the safety of such data.
Rights and control mechanisms
As a resident of the European Economic Area you have the following rights in relation to your Personal data:
Right of access. You have the right to access your Personal data i.e. the right to require free of charge (i) information whether your Personal data is processed, (ii) access to and/or (iii) duplicates of the Personal data processed. Innova reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested.
Right to rectification. 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 by contacting Innova or by messaging support team of the Game as specify in the Contacts.
Right to erasure. User has the right to request a deletion of User’s Personal data by requesting for account deleting via support, which will lead to the loose of access to 4game Service and Games.
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.
Right to data portability. User has the right to request for transfer of User’s Personal data directly from Innova to another controller, where it is technically feasible.
User is always welcomed while he or she desires to realize any of his or her Rights related User’s Personal data. For such purposes please contact us as specified hereinbelow. In case of any questions or requests related your Personal data you can contact us by email or by post (for the postal address) or you may addresses your request to the support team at: eu.4gamesupport.com. The User acknowledges that all requests shall be made in English, the replies will be in English as well. Please don’t forget to identify yourself and provide User name, e-mail address and other necessary information in your request.
Innova Co. S.à r.l.
16 RUE ERASME
e-mail: firstname.lastname@example.org or email@example.com
If this document is modified in any way, Innova will place an updated version of it on the following pages: eu.4game.com.