This Privacy Policy describes how Innova Co. S.à r.l. ("Innova," "we," or "us") processes your personal data when you use our services.
This policy applies to the following:
- Our Website: https://eu.4game.com/ (the “Website”)
- the Inn.games Application at https://eu.4game.com/ (the “Inn.games Application”)
- Our Online Games available through the Inn.games Application (the “Games”)
- Our Forum: https://eu.4gameforum.com (the “Forum”)
- Any other services we offer that link to this Policy.
For the purposes of this document:
• The Website and the Inn.games Application are together the "Inn.games Service."
• The Inn.games Service, Games, and any other covered services are collectively the "Services."
If we decide to amend this Privacy Policy, we will post a new version on the Website and provide a notice within the Inn.games Service. However, we encourage you to review this Policy periodically for any changes. We may update our cookie list (with amendment dates) without changing this Policy unless significant changes require a new version.
This Policy exclusively covers Innova's data handling and does not apply to third parties we do not own, control, or direct. If you share your personal data with such third parties, including through the Inn.games Service or via links on our websites, please ensure you have read and agreed to their respective privacy policies. We are not responsible for their privacy practices.
Please note your use of the Inn.games Service is subject to the terms available here https://eu.4game.com/legal/4game/
1. CONTACT US
Unless otherwise specified, Innova Co. SARL acts as the data controller for the personal data we process under GDPR.
To contact us about this Privacy Policy, please use any of the following methods:
- e-mail: privacy@inn.eu
- mail: Address: 16 Rue Erasme, L-1468 Luxembourg
If you have questions about the Games, please contact support at:
support.eu.4game.com.
2. CHILDREN’S PRIVACY
The use of the Services by minors is subject to prior parental consent and supervision. We do not knowingly collect, store, or process personal data from users under the age established by applicable law without the consent of their parent or legal guardian.
If you are under the age of digital consent in your country, please do not use, download or register for the Inn.games Application and do not provide us with any personal information. If we become aware that we have unintentionally collected personal data from a child without the required parental consent, we will promptly delete that information from our servers.
Parents or Guardians: If you believe your child has provided us with their personal data without your consent, please contact us immediately. We will take all necessary steps to delete such information from our records, unless we are required to retain it by law.
3. HOW AND WHAT DATA WE RECEIVE ABOUT YOU
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 ethnic origin, biometric data, health data, your political, religious or philosophical beliefs, trade union membership, genetic data, health or sex life or sexual orientation, or any other personal data concerning fundamental rights and freedoms.
The specific data we collect may differ depending on how you use our Services.
We may collect and process the following categories of your personal data in the ways described below.
A. Data we may receive directly from you
Most of the personal data we process we obtain directly from you. This includes data you provide when you:
(i) Create an account on the Inn.games Service and use the Services
When you create an account for Inn.games Application, we collect: first and last name (optional), login (username), password, security question and answer (optional), nickname of your character, email address, phone number (optional), date of birth, gender (optional), country (optional), avatar (optional), and a link to your social network profile (if provided), game server you chose. We do not expect the User to upload real photos as avatars.
Important: Providing your first and last name is fully optional. However, if a payment-related issue arises, this information allows us to resolve it quickly and accurately.
(ii) Contact us
If you contact our support team or otherwise get in touch with us (e.g., with requests, inquiries, or complaints), we collect the information you provide. This may include your name, contact details, email address, security answer, region, payment dates and amounts, and the reason for your communication. If you submit a refund request, we may ask for payment confirmation, such as a screenshot from your payment account showing the transaction amount, number, and time.
(iii) Participate in our events or programs
If you join our online or offline events, meetings, loyalty programs or similar initiatives we may collect the following information: your name and contact information, your image (e.g., if you attend in person or a winner), winner's data needed to award a prize, including your delivery address; details about your use of promotions or loyalty programs, information about your preferences and interests, etc.
(iv) Participate in our surveys, polls, or game tests
If you chose to participate in surveys, polls, or testing of our Games, we receive information about your preferences and interests, Discord nickname, your feedback on our services, testing results, and your in-game statistics.
(v) Create and use an account on our Forum
When you create and use an account on our forum, we collect your nickname, email, date of birth, and password. As you use the Forum, we also receive your text messages and any other content you share. You may also choose to provide additional information, such as your avatar, gender, location, occupation, homepage link, the Games you play, and details about your server, clan, race, and class.
(vi) Use in-game chats
When you use in-game chats, we receive your text messages and any other content you share.
Important note on in-game chats and the Forum: Please be aware that information shared in chats and the Forum may become public or be used by others in unexpected ways (e.g., messages might be re-sent, or gameplay streamed with your messages visible). We advise you to be mindful of the information you share. We also ask that you avoid sharing personal data or information that could identify you with third parties within chats.
B. Data we collect automatically
We automatically collect certain information when you use our Services, including:
Device and Technical Information:
- an automatically generated unique User ID
- IP address; country information (approximate geographical location derived from your IP address);
- Unique device identifiers, MAC address, and other network/Wi-Fi identifiers;
- Device specifications (device model, processor, RAM, CPU, graphics card, available disk space, screen size, battery, etc.);
- Software environment (operating system, browser, installed applications, antivirus solution, Inn.games Application version);
- Language settings
Network and Connection Data:
- Internet Service Provider (ISP) and network type (e.g., Wi-Fi, 4G).
- Diagnostic data about your connection to our servers.
How You Use Our Services:
- Your in-game actions, progress, playtime, and character data.
- Interaction data (clicks, scrolling, browsing times).
- Standard server logs (time and date of access, pages visited, error reports).
- Referral Information: Web pages that led you to our Website.
Financial Information:
- Your Inn.games account balance; transaction details (date, time, amount, and currency).
Cookies and Similar Technologies:
Cookies. When you use our Website, we may collect certain information about your interaction with the Inn.games Service through cookies and similar technologies. For details on the cookies we use, please see our Cookie Policy (https://eu.4game.com/legal/4game/152/ ).
reCAPTCHA: When you use our Website and Forum, we employ Google's reCAPTCHA service to protect against automated bot activity. This service automatically processes certain data from your device and interactions (such as mouse clicks, touch events, and page interactions) to assess whether you are a human user. This processing is subject to Google's Privacy Policy https://policies.google.com/privacy?hl=en
C. Data we may receive from Third Parties
In certain cases, we may obtain information about you from third parties. This can occur in the following scenarios:
- From payment services: we receive information about your card PAN (last 4 digits) and bank name, billing address, payment system user ID, payment confirmation signature, date and time of the payment. We only collect data to verify payments and do not have access to full payment data.
- From Third-Party:
- From analytics and marketing partners: We receive analytical and/or statistical data from third parties such as our marketing/advertising partners and analytics partners.
- From other users: We may receive information about you if another user of the Game(s) files a complaint that refers to you.
- From public authorities: we may receive relevant information from public authorities, regulators, and/or law enforcement bodies if we receive an inquiry concerning you.
- From online resources: We may monitor publicly available content and sentiment in our official communities on social networks or other platforms to understand community feedback and trends. In rare cases, if you publicly post content that suggests a potential for collaboration (e.g., high-quality fan creations), we may use your public profile information (e.g., username) to contact you. We do not systematically collect or store personal data from these sources in our databases
When You Connect a Third-Party Account:
If you choose to link your Facebook, Google, or Twitch account to our Service for purposes like authorization or rewards, we will receive certain profile information from that provider. The data we receive depends on the provider's privacy policy and your privacy settings with them.
Google: We may receive your email address.
Facebook: We may receive your social network identifier.
Twitch: We may receive your username, confirmation of the connection, and other relevant usage or diagnostic information.
From the сhat-bot service provider (Telegram): When you use our chat-bot service, we may receive publicly available information from your Telegram account. This can include your display name (which may be a pseudonym), username, a brief description about you from your account, profile photos, and messages you send through the chatbot. For more information on Telegram's privacy practices, please refer to their Privacy Policy: https://telegram.org/privacy?setln=en
4. PURPOSES AND LEGAL BASIS FOR DATA PROCESSING
Below you can find details on why we process your data, the types of data we process for this purpose, and the legal basis for our processing activities.
| Purpose | Legal basis | Categories of data processed (non-exhaustive) |
to identify you in the Inn.games Service and our Games
| contract with you | User ID, nickname of your character |
| to help identify you as the payment initiator in the event of a transaction dispute, claim, or refund request initiated by you | our legitimate interest to resolve disputes, protecting against unfounded claims, and securing financial operations | first and last name. Providing you’re your first and last name is optional |
to log and authenticate in to your Inn.games account
| contract with you | your email address or your username and password.
a link to your social network profile (if provided) If you choose to link your Facebook account: the data provided by Facebook to enable login, which may include a unique identifier
|
| to provide you with optional methods to restore your account access and enhance its security (e.g., if you lose access to your primary email) | our legitimate interest to ensure the security and recoverability of user accounts | security question and answer, and/or phone number. Providing this information is optional |
| to customize your profile | our legitimate interest to meet the needs of our users
| your avatar |
for internal analytics and, where you have provided this information, to better understand our audience and tailor our service, marketing offers, and content to be more relevant
| our legitimate interest to develop our services and business and meet client interests | your gender. Providing your gender is entirely optional. It will be used only in aggregated, anonymized form for analytics or for personalization if you have chosen to provide it. You can update or delete this information in your profile at any time
|
| to provide you with the necessary support, handle your claims, requests, and/or your complaints | contract with you | information you provide when you contact us: your first and last name, contact data, email, security answer, your region, payment dates and amounts, etc |
to provide you with electronic newsletters and/or our marketing/promotional notifications
| your consent | your email |
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.
| contract with you | your name and contact information, your image (e.g., if you attend in person or a winner), winner's data needed to award a prize, including your delivery address
|
| to conduct surveys, questionnaires | our legitimate interest to improve our Service | data about your use of promotions or loyalty programs, data about your preferences and interests
|
| to conduct playtests | our legitimate interest to improve our Service
| your email, discord nickname, testing results
|
| to provide you with the services of in-game chats, the Forum, Telegram bots | contract with you | text messages and other content you share in-game chats, our Forum, Telegram chatbot
|
to identify you on the Forum and log in to your Forum account
| contract with you | nickname, email, and password
|
| to verify that you meet the minimum age requirement to register and use the Forum and the Inn.games Service and, if necessary, request the consent of your legal representative in compliance with child data protection laws | our legal obligation to protect underage users and obtain parental consent | your date of birth |
to analyze the usage of the Forum |
our legitimate interest to improve our Service |
game you played, server, clan, race, class and any additional details you choose to share about yourself
|
| to protect the Inn.games Service and our users against DDoS attacks, hacking, fraudulent access, unauthorized modification, and other illegal activities (e.g., by analyzing and blocking malicious IP addresses) | our legitimate interest to ensure security and stability of the Services | IP address; unique device identifiers, MAC address, and other network/Wi-Fi identifiers |
| to enforce territorial restrictions in accordance with the licensing terms of the content we distribute, preventing access to the Service from territories where it is not authorized | our legitimate interest to comply with licensing agreements with rightsholders
| country information (approximate geographical location derived from your IP address) |
| to determine the cause of the service failure, fix bugs | our legitimate interest to ensure the operation of our Inn.games Service | software environment; antivirus solution; network and connection data; diagnostic connection data
|
| to update the Inn.games Service to the latest version | our legitimate interest to improve our Service | Inn.games Service application version |
| ||
to analyze the usage of Inn.games Service, develop and improve the Service, fix bugs, develop new tools and products, and to provide you with new features within the Service
| our legitimate interest to improve our Service
| device specifications, language settings, service usage and analytics Information about actions on the Inn.games Service, playtime
|
| to develop and improve the Game(s), develop new tools and products, and to provide you with new features within the Service | our legitimate interest to improve our Service
| information about your preferences, testing results, and your playtest statistics, your feedback from official social media groups on social networks or other online resources |
| to provide you with the Game(s), to save progress in the Game(s), etc. | contract with you | game server you chose, in-game items, payment amount purchased, and payment dates and time logs, and data on in-game transactions, Game progress, game character actions, log files
|
to process your payments, purchases and returns
| contract with you | financial Information: transaction details, account balance
|
| to fulfil our tax obligations | fulfillment our legal obligation | purchase data and country information
|
| to analyze the effectiveness of our advertising | our legitimate interest to manage and operate of our business effectively
| referral Information: web pages that led you to our Website
|
| to investigate, handle, and prevent improper use of the Service, violations of terms of use of the Game(s), fraud, cheating, and in-game violations | our legitimate interest to protect our players from fraud | User ID, data on the organization of game process and information about in-game character activities, game data and commands, and the log files |
to analyze general public feedback, sentiment, and suggestions regarding our Services from our official communities on social networks or other public online resources. This helps us understand community trends and may inform our development and communication strategies
| our legitimate interest to improve our Service and engage with our community based on publicly available information | publicly available content and feedback from our official communities on social networks or other online resources. We do not collect your personal data from these sources in a structured manner. This refers to our team's review of publicly available posts, comments, or discussions in our official communities.
|
| to provide you with Telegram chat-bot services | our legitimate interest to meet the needs of our users | publicly available information from your Telegram account: display name on Telegram (which may be a pseudonym), username, a brief description about you from your account, profile photos
|
| to verify your participation and provide you with rewards for our promotional campaigns (e.g., when you connect your Twitch account to participate) | our legitimate interest to operate and administer our promotional campaigns | data received from Twitch when you connect your account: your Twitch username, confirmation of the connection, and necessary activity data (e.g., stream watch time) to verify eligibility for the reward |
to distinguish your request from automated requests
| our legitimate interest in protecting us from spam | data about your activity through service reCAPTHA on our Website and the Forum |
For information about the legal basis and purposes for which we use cookies, please see our Cookie Policy https://eu.4game.com/legal/4game/152/
5. HOW WE MAY SHARE YOUR DATA
Innova does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your personal information to any third party for monetary or other valuable consideration.
However, we may share your data in limited circumstances with the following third parties:
A. Data storage partners
We store data we collect about you on servers provided by our third-party service providers, such as Hetzner (privacy policy https://www.hetzner.com/legal/privacy-policy),
G-Core (privacy policy https://gcore.com/legal?tab=privacy_policy),
and Amazon Web Services (privacy policy https://aws.amazon.com/privacy/).
B. Payment systems
We may transfer your data to our payment systems if this is necessary to process our payment request. The list of such data may vary and include your email address, IP address, User ID, status of the user confirmed or not, and other information, and depends on the requirements of the payment service.
In case of requests from payment systems regarding user chargebacks, we can provide data on purchase logs, payments, information on purchased goods, and on the account
The list of available payment methods (payment systems, payment agents) that you may use for payments, and with which Innova may share your data, is available in the "Replenish account" section of your account profile within the Inn.games Application.
PayPal https://www.paypal.com/myaccount/privacy/privacyhub
Klarna https://www.klarna.com/international/privacy-policy/
Przelewy24 https://www.przelewy24.pl/en/information-obligation-gdpr-payer
PaysafeCard https://www.paysafecard.com/en-gb/privacy-notice/
Skrill https://www.skrill.com/en/comprehensive-privacy-notice/
C. Game developers and rights holders
We may share non-personally identifiable information with our partners, such as developers or rights holders. This information includes, at a minimum, your use of the Game(s). It may also include your progress in the Game(s), completed achievements, in-game items, and other data needed to analyze, improve, and fix game-related issues.
D. Innova’s analytics and advertising partners
We share information with analytics and advertising partners to improve our services and advertising effectiveness. This includes data about your device and website interactions.
Our partners and why we share data with them:
Google Services (Analytics, Ads, Tag Manager, Marketing Platform): For web analytics, ad management, conversion tracking, and campaign execution. Privacy Policy: https://policies.google.com/privacy
Meta (Facebook Pixel and Ads): For measuring ad effectiveness, analyzing on-site actions, and building audiences for Facebook/Instagram campaigns. Privacy Policy: https://www.facebook.com/privacy/policy/
Yandex (Direct and Metrica): used for the Website usage analysis and marketing funnel optimization. Privacy Policy: https://yandex.com/legal/confidential/en/
Kool Things Sp. z o.o.: For optimizing marketing campaigns and finding new, similar audiences. Privacy Policy: https://koolthings.com/privacy-policy/
Optimove: For personalizing marketing campaigns, analyzing user data, delivering email communications, and personalized customer marketing. Privacy policy: https://www.optimove.com/legal/privacy-policy
Affise: for researching and analyzing how our Services are used, as well as for error analysis. Innova may also aggregate this data for benchmarking purposes. Privacy policy: https://affise.com/privacy-policy/
Admitad, Advgame, and Adtogame
We use tracking technologies, such as pixels and SDKs, from our partners to attribute traffic, track conversions, and reward partners for successful referrals. These partners may process data outside the European Economic Area (EEA). In such cases, we rely on Standard Contractual Clauses (SCCs) to ensure an adequate level of protection for your personal data. These tools are used only with your consent. Their respective privacy policies: Admitadhttps://www.admitad.com/privacy/ Advgame https://advgame.com/privacy/, and Adtogame https://adtogame.com/.
Detailed information regarding the specific technical tools (cookies, pixels, SDKs) used by these partners, data retention periods, and instructions on how to opt-out of tracking can be found in our Cookie Policy.
E. Other services
To provide you with a secure and functional service, we also share your information with the following types of partners:
Google reCAPTCHA: To protect against spam, our Website and the Forum have a captcha from Google Inc. Privacy policy: https://cloud.google.com/security/products/recaptcha https://policies.google.com/privacy
Communication Services: to send you essential emails and text messages (SMS).
Innova may also use local storage technology of the following partner networks: YouTube, Meta and X Platform. You can find further details on data privacy policies via the following links:
for YouTube: https://policies.google.com/privacy?hl=en,
for Meta: https://www.facebook.com/about/privacy/,
for X Platform: https://x.com/en/privacy .
F. Innova’s subsidiaries and affiliates
As a global company, we process information in our offices worldwide, including outside the European Economic Area (EEA) and other jurisdictions where Innova, its affiliates, or subsidiaries operate.
All personal data is handled confidentially and accessed only by Innova or its affiliates. When shared with subsidiaries or third parties, we ensure an adequate level of protection, including: Data Processing Agreement (DPA), and Standard Contractual Clauses (SCCs) as approved by the European Commission.
G. Change of control
In the event of a merger, acquisition, sale of assets, or other change of control, we may share your personal data as part of the transaction. The receiving party will only be permitted to use your data in accordance with this Privacy Policy.
H. Additional cases, when we may share information:
- Game Violation Detections: Information about the user’s in-game activities, logs, and transaction data - used for detecting game violations to prevent or punish cheating and unfair play - may be disclosed to that user;
- Legal Requirements: Your data may be disclosed without your consent if required by law. For example, this could happen upon request from the competent authorities, public entities or bodies, our auditors, banks, and other competent parties acting under European Union or relevant Member State law;
- Defense of Rights: We may share your data when defending and/or enforcing our rights (including those of our affiliates), in the event of litigation between Innova and the User, or if Innova receives a request from a competent authority;
- Event Participation & Prizes: If you participate in our events and/or win prizes, we may share your necessary contact data with our travel and logistics partners (or instruct you to do so yourself) to arrange your travel and/or prize delivery.
TRANSFER OF PERSONAL DATA OUTSIDE THE UK/EU/EEA
We transfer personal data outside the UK/EU/EEA/Switzerland using Standard Contractual Clauses (SCCs) and other EU-approved transfer mechanisms.
All transfers comply with applicable data protection laws. We implement appropriate safeguards (including EU-approved data protection clauses) to ensure your data remains protected when processed internationally, and, where required, apply supplementary technical and organizational measures to ensure an essentially equivalent level of data protection.
Specifically, we transfer personal data to service providers and partners located in the following countries outside the EU/EEA/UK: the United States (e.g., Google, Meta, Amazon Web Services), and the Russian Federation (e.g., Yandex services, Advgame).
6. HOW LONG WE STORE AND PROCESS YOUR DATA
We store and process your personal data for as long as necessary to fulfill the purposes for which it was collected, or until you request the deletion of your personal data, unless there are legal grounds for longer retention. Examples of retention periods for certain data categories are provided below:
- Purchase Data: We store personal data related to your purchases (such as transaction ID, purchase date, item details, payment amount, country information) for as long as necessary to comply with our legal obligations under applicable tax, accounting, and other laws.
- Account Registration Data, Device Data, and Support Interaction Data: We store registration data for your account, device information, and details about your inquiries for one year after the termination of our agreement with you.
- Game-Related Data: Data related to the use and organization of the game (including, but not limited to: information about your in-game character's actions, game data and commands, transaction details, and log files) is stored for the following periods:
- Forum Messages: We store messages from the Forum until the user deletes their account or until we receive a user request for data deletion.
- Dispute Resolution Data: In the event of a dispute with a user, we will additionally store data necessary for asserting, exercising, or defending legal claims for the applicable statute of limitations or until the related legal dispute is resolved.
- Cookie Data: Data collected via cookies is stored for the periods specified in our Cookie Policy.
General Retention Period: One (1) year from the date of collection for all game data, unless specified otherwise below.
Specific Log Files:
- Game logs for Lineage are retained for a maximum of 30 days.
- Game logs for Ragnarok are deleted annually on January 1st.
You can delete your personal data by removing it from your Account, completely deleting your Account, or by contacting our support service.
7. HOW DO WE PROTECT YOUR DATA
Innova uses necessary safeguards to protect your personal data. All information sent to us is encrypted using Secure Socket Layer (SSL) technology. We also implement various technical and organizational measures to protect your data, including:
- Access Control: Personal data is accessible only to authorized personnel, who require it for their job functions.
- Data Minimization & Retention: We collect only the necessary data and set clear retention periods for personal data.
- Security Safeguards: We use anonymization or pseudonymization techniques, and other electronic, physical, and procedural safeguards, as is standard in the industry.
- Human Oversight: Our data processing mechanism includes provisions for human intervention.
8. AUTOMATED DECISION-MAKING AND ONLINE TRACKING/
We do not rely solely on automated processing, including profiling, that could have legal or similarly significant effects on you.
9. YOUR RIGHTS REGARDING OUR PROCESSING OF YOUR PERSONAL DATA
You have certain rights regarding the personal information we hold about you. Some of these rights may have exceptions or limitations. To exercise your rights, outlined in this section, please contact Innova at any time by sending your requests to: privacy@inn.eu
You have the following rights regarding the data that we process:
A. Right of access
You can request information about the data we process about you, including: the purposes of processing, categories of personal data held, recipients of your data, storage periods, and to receive a copy of it.
B. Right to rectification
If the data we hold about you is incorrect, incomplete, or outdated, you can request that we correct or complete such information by contacting Innova.
You can also delete your personal data directly in your account and make changes or corrections to your information there.
C. Right to delete (“right to be forgotten”)
You can request to delete your personal data unless we are legally required to continue processing it (for example, to comply with our legal obligations or to protect or enforce our legal rights). Please note that deleting your data will lead to loss of access to the Game(s) and all associated progress/data.
D. Right to restrict processing
You have the right to entirely or partially restrict the use of your data in certain circumstances unless we are legally required to continue processing some of your personal information.
E. Right to object
If we process your data based on a legitimate interest, you have the right to object to this processing unless there are compelling and prevailing legitimate grounds for the processing, especially if the data is necessary for the establishment, exercise or defense of legal claims.
F. Right to data portability
You have the right to receive your data in a structured, commonly used, and machine-readable format and ask us to transfer your data to another controller where technically feasible.
G. Right to withdraw consent
When your data is processed based on your consent, you have the right to withdraw that consent at any time.
Opting Out of Marketing Communications
If you no longer wish to receive promotional messages, news, event, and tournament information from us, you can opt out by adjusting your account settings on the Inn.games Application. To do this, log in to your account, go to the "Mailings and notifications" section, and uncheck the categories you are not interested in.
Managing cookie preferences
You can manage your cookie settings on our Website. To do this, go to the Website, select "Cookies preferences" in the footer, and uncheck the box for "Optional cookies."
Please note that you cannot refuse the collection of essential cookies, as they are necessary for the Website to function correctly. Also, disabling cookies in these settings will not automatically delete them from your device; you should clear them directly through your browser settings.
H. Right to lodge a complaint with the supervisory authority
You have the right to file a complaint with the relevant data protection authority, particularly in your country of residence, your place of work, or our location.
As Innova Co. SARL is incorporated in Luxembourg, the National Data Protection Commission (CNPD) serves as our supervisory authority. You may contact them at:
15, Boulevard du Jazz, L-4370 Belvaux
Website https://cnpd.public.lu/en.html