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