GameCredits respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation (“GDPR”).
Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual (“Personally Identifying Information”) or that can be connected to you indirectly by linking it to Personally Identifying Information. GameCredits may also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. GameCredits may share anonymous data, aggregated or not, with third parties.
2. Why GameCredits Collects and Processes Data
GameCredits collects and processes Personal Data for the following reasons:
a) where it is necessary for the performance of our agreement with you to provide a full-featured gaming service and deliver associated Content and Services;
b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
c) where it is necessary for the purposes of the legitimate and legal interests of GameCredits 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; or
d) where you have given consent to it.
These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).
3. What Data We Collect and Process
3.1 Basic Account Data
When setting up an Account, GameCredits will collect your email address and country of residence. You may also be required to choose a user name and a password. The provision of this information is necessary to register a User Account. During setup of your account, the account may automatically be assigned a number (the “ID”) that is later used to reference your user account without directly exposing Personally Identifying Information about you.
3.2 Transaction and Payment Data
In order to make a transaction on the GameCredits store (e.g. to purchase Subscriptions for Content and Services), you may need to provide payment data to GameCredits to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to GameCredits, which GameCredits will process and transmit to the payment service provider to enable the transaction and perform anti-fraud checks. Likewise, GameCredits will receive data from the payment service provider for the same reasons.
3.3 Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others on the website. This data includes:
• Information that you post, comment or follow in any of our Content and Services;
• Information sent through chat;
• Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant or, in case of physical goods, shipping providers;
• Information you provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details.
3.4 Your Use of the GameCredits Client and Websites
We collect a variety of information through your general interaction with the website and Content and Services offered by GameCredits. Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data. Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our services.
3.5 Your Use of Games and Other Subscriptions
In order to provide you with services, we need to collect, store and use various information about your activity in our Content and Services.
3.6 Tracking Data and Cookies
3.7 Google Analytics
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.
3.8 Marketing Messages
Subject to your separate consent or where explicitly permitted under applicable laws on email marketing, GameCredits may send you marketing messages about products and services offered by GameCredits to your email address. In such a case we may also use your collected information to customize such marketing messages as well as collect information on whether you opened such messages and which links in their text you followed.
You can opt out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the “unsubscribe” link provided in every marketing email.
3.9 Information Required to Detect Violations
We collect certain data that is required for our detection, investigation and prevention of fraud, cheating and other violations of the Terms of Service and applicable laws (“Violations”). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on of such Violations 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.
4. How Long We Store Data
We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
If you terminate your GameCredits User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage. In certain cases Personal Data cannot be completely deleted in order to ensure the consistency of the gameplay experience. Please note that GameCredits is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years. If you withdraw your consent on which a processing of your Personal Data or of the Personal Data of your child is based, we will delete your Personal Data or the Personal Data of your child without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent. If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
5. Who Has Access to Data
5.1 GameCredits and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in section 2. above. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.
5.3 In accordance with internet standards, we may also share certain information (including your IP address and the identification of GameCredits content you wish to access) with a third party network providers that provide content delivery network services and game server services in connection with GameCredits. Our content delivery network providers may enable the delivery of digital content you have requested, e.g. when using the GameCredits store, by using a system of distributed servers that deliver the content to you, based on your geographic location.
5.4 The GameCredits community may include 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 will be made publicly available online; therefore, you are doing so at your own risk. If your Personal Data is posted on one of our community forums against your will, please use the reporting function to request its removal.
5.6 GameCredits may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.
6. Your Rights and Control Mechanisms
The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their Personal Data. While other jurisdictions may provide fewer statutory rights to their citizens, we make the tools designed to exercise such rights available to our customers worldwide.
As a resident of the European Economic Area you have the following rights in relation to your Personal Data:
6.1 Right of Access
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through our Contact page: https://gamecredits.org/contact-us/. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we 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) or refuse to act on the request.
6.2 Right to Rectification
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided via the Contact page: https://gamecredits.org/contact-us/.
6.3. Right to Erasure
You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion. For such requests, visit the Contact page https://gamecredits.org/contact-us/.
In some cases, deletion of your GameCredits User Account, and therefore Personal Data deletion, is complicated. 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.
6.4 Right to Object
You also have the right to lodge a complaint at a supervisory authority.
6.5 Right to Restriction of Processing
You have the right to obtain restriction of processing of your Personal Data under the conditions set out in article 18 of the GDPR.
6.6 Right to Portability
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in article 20 of the GDPR.
6.7 Right to Post-Mortem Control
If French data protection legislation is applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of Personal Data after your death in accordance with article 40-1 of the Act No 78-17 of 6 January 1978 on Information, Technology, Data Files and Civil Liberties.
GameCredits will not knowingly collect Personal Data from children under the age of 13. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, GameCredits requires parental consent before Personal Data can be collected. GameCredits encourages parents to instruct their children to never give out personal information when online.
8. Contact Info
You can contact GameCredits’s data protection officer at the address below.
While we review any request sent by mail, please be aware that to combat fraud, harassment and identity theft, the only way to access, rectify or delete your data is through the Contact page: https://gamecredits.org/contact-us/.
Game Credits Inc.
Attn: Data Protection Officer
324 Sunset Ave., Suite D
Venice, CA 90291
Revision Date: March 7, 2019