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Privacy policy

Innova takes care about the security of your personal data. This document (referred as “Privacy Policy” or “Policy”) contains information about User’s data collected by Innova and terms of data processing when using services of Innova.

Without acceptance of this Privacy Policy you may not use our services. By accepting this Policy you make the explicit and specific consent to the processing of your personal data in accordance with the purposes and in the manner described herein.

This Policy applies to all official websites of Innova, where it is placed (published) and through which you get access to our services, as follows:

This Policy is based on the principles set forth in the Directive of October 24, 1995 Directive EU 95/46/EC and the modified Luxembourg law of 2002 on protection of individuals in relation to the processing of personal data (hereinafter the “Law on Personal Data”).

The purpose of processing of your personal data is specified in this Policy. We will notify you on any changes in advance and ensure of your consent.

Innova does not transfer your data to anyone, except for those specified in this Policy or as provided by the Law on Personal Data, 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.

Innova does not collect data in relation to Users’ racial and ethnical origin, their political, religious or philosophical beliefs, trade union membership, genetic, health or sex life. You should be aware that in case you at your own discretion post (publish) you personal data on forums or use them as your login or as character’s names (disclose), your data become available and known to the public and you become responsible for the consequences of such disclosure.

Innova does not enter into a contract or collect data of persons under the age of 18. Persons above 13 years but 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. At any time Innova may contact with the User and request contact details of legal representatives and/or their consent mentioned above.

Where applicable, all User’s rights and obligations to this Policy are exercised exclusively through their legal representatives.

Personal information provided by the user for purposes of performance of the agreement

Innova collects and processes your personal data for the purposes of the registration (creation) and operation of a 4game account. For example, but not limited to: accessing to the 4game account, formation and performance of the agreement, game services and game access, processing of support tickets, payments acceptance etc.

For these purposes Innova requires and collects the following “ Compulsory Data ”:

1) Obligatory data, such as:

  • e-mail address
  • User’s ID in social network that is used for registration at 4game
  • place of User’s residence and

2) In order to perform agreements in respect to the game service, Innova may collect “Additional Data” such as:

  • cell phone number
  • full name
  • date of birth
  • sex
  • partial number of User’s ID document

Providing this Additional Data is not always necessary, but might become obligatory for the relevant Game. We will inform you about it in the appropriate agreement regarding the game.

These Additional Data are also collected for the purpose of protection of your account from hacking and hacker attacks. You may also freely provide such information to Innova without our request.

Innova also may collect non-personal information 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 mentioned in this Policy.

Compulsory Data provided by Users are stored for the whole validity period of relevant agreements with Innova, but in any case for accounting or tax records such data are kept for the period no longer than 5 years after the termination of the User agreement, if there would be no legitimate reason to keep it longer.

Compulsory Data is necessary for the provision of Innova’s services. Request of deletion of such data will result in your inability of using Innova’s services.

Furthermore, Compulsory Data may be collected in the following cases:

  • while contacting Innova via e-mail, fax, phone or mailing address of Innova;
  • while contacting the support team;

Innova keeps correspondence with the user (support calls (tickets), notifications sent to the user’s e-mail and received from users, which can be used to analyze the improvements made in services, answers to users’ questions, while restoring access to the user’s account, in case of loss of payment, etc.

While restoring access to your account (for example, in case of fraudulent access and/or hacking attempts), in case of loss of payment, suspected fraud, 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 of the data, and left to your discretion. This information is stored for 1 year after the termination of the User agreement if there would be no legitimate reason to keep it longer.

Payment data collection for purposes of using fee-based services

When the User tops up his or her 4game account via payment systems (payment agents), specified by 4game, Payment Data is exchanged between Innova and the payment system that includes:

  • user ID in the billing of Innova;
  • 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)

For example, when you top up your 4game account via the payment system PayPal, the following information is additionally processed:

  • 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).

When using credit cards the following information may be additionally processed:

  • name of the cardholder;
  • masked card number — 12 symbols and last 4 digits;
  • country code (if applicable);
  • address (if applicable).

Payment Data is stored for 5 years as required by the financial and tax legislation.

Collection of data for participation in promotion (marketing or advertising event)

Innova may use your data, including e-mail and/or phone, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about services of Innova and its affiliates. If you do not wish to receive such information, you can unsubscribe from such e-mails following the instructions as described in the corresponding messages or via 4game account interface.

Collection of data for service notification

Innova may also use your e-mail and/or phone information for sending service notifications, for example, in case of password restoring, reply to your request or other messages directly related to controlling access to services of Innova. You can disable this feature at any time, but you will be unable to use such features, for example, you will not be notified if there was a login to your account.

Collection of non-personal data for improvement and development purposes

In order to provide quality services and to justify your expectations of the services, 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 the user’s computer to servers of Innova, trace route information between your PC and servers of Innova, etc. The company processes such data also for evaluation in development plans, performance of updates and bug-fixing.

This information is stored for 1 year and helps to prevent or resolve technical issues at the beginning or during the use of services of Innova.

IP (internet protocol) address

When you visit websites and or use services of Innova, we may gather and store the information about your IP address to determine your approximate geographic location, which allows us to provide you with information and services available or intended for the territory where you are.

Also, information about the IP address is used to prevent illegal use of Innova’s services if there is reasonable suspicion, in order to ensure the security of Innova’s servers (i.e. blocking of concurrent IP addresses). The data on the IP address is stored for 1 year.

Cookies

Cookies are small pieces of information stored by your internet browser on your computer’s hard drive. Like most website providers, Innova uses cookies to make a link between you and the information you have provided to our website and therefore provide you with personalized content so that we can give you a better experience when you return. In order to benefit from such features you should accept and enable the use of cookies.

Innova would like to point out that if you choose not to accept cookies you will not be able to fully use all of the functions of our website and the 4game, including paid services. 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.

Collection of data for organization of game process

Innova collects data on the game process, 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). These 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.

If game account or character was banned based on logs or chat correspondence, such data are stored for 3 years after the violation if there would be no legitimate reason to keep it longer.

In case with 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 has request from the authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.

Security 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.

Data storage

Innova stores data and information during the time periods specified in this Policy or until receiving your request for removal of personal data, if there is no legitimate reason to keep them longer.

Personal data cannot be deleted or anonymized when it is necessary to comply with legal requirements. If you wish to change and/or remove your personal data then you may lose the ability to use the services of Innova from the date when your request is completed. When your data is incorrect or inaccurate you may either amend it on your own or ask Innova’s specialists to do this.

Financial information cannot be changed and/or removed at your request unless you provide Innova with the documentary approval of necessity making such changes.

Innova doesn’t delete the data if any violation or abuse has been occurred from Users side or Innova has been summoned not delete the data by a governmental authority request or a court order. If a User requests the removal of all his personal data, while a prior request (s) from that User is still being processed, such data can be deleted only when the User has recalled/cancelled all previous requests.

Innova stores the log files within the periods specified in section “Collection of data for organization of game process”.

The data are 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.

The user can modify and/or delete 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 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).

The requested information is provided to you in electronic form. Provision of it 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 reasonable time period.

The data collected will be treated confidentially and used only by Innova or Innova’s affiliate (Innova Systems LLC.). 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 authorizationsDepersonalized data can be transmitted to the Right holder (NCsoft, the Republic of Korea).

Data with User’s e-mail can be processed by the Innova’s partners (Innova Systems LLC) which shall treat the personal data strictly in accordance with this document and to use it only for services related purposes or transactions in behalf of Innova.

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.).

Without your consent the data may be disclosed in cases required by legislation, for example, at 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 using your personal data as name of game character, you should be aware that these data are publicly available and can be used by third parties, and Innova ceases to be responsible for the safety of such data.

Сontact

User is always entitled to request information about any of his/her data that Innova has stored, as well as request for correction or deleting of any of his/her personal data.

User shall contact the following and also provide User name, e-mail address and other necessary information regarding subject of his/her request:

Innova Co. S.à r.l.

16 RUE ERASME

L-1468 Luxembourg

e-mail: innova@inn.eu

If this document is modified in any way, Innova will place an updated version of it on the following pages: eu.4game.com.