Introduction

1D3 DIGITECH OÜ (hereinafter – “1D3” or “we”) understand that You are aware of and care about Your personal data protection, and we take that seriously. This Privacy Policy describes how we collect, process, use and share Your personal information when You use our website, download and play our games and use other products, as well as sets forth Your privacy rights. We recognise that personal data protection is an ongoing responsibility, and we may from time to time update this Privacy Policy, as we undertake new personal data processing practices. We are fully dedicated to ensuring that our personal data processing practices are in line with the requirements of GDPR.

“You” in this Privacy Policy may refer to a visitor of our website (hereinafter – “Visitor”), customer who intends to use or already installs, uses or otherwise accesses the Software and (or) uses our products or services, (hereinafter – “Customer”) or a person that develops or licenses the Software (hereinafter – “Partner”).

Controller of personal data

1D3 is a controller of personal data processed under this Privacy Policy. 1D3 determines the purposes and means of processing of these personal data. 1D3 is responsible for exercising the rights of the data subjects and for provision of the information to the data subjects.

Information we may collect from you

Personal data:

We may collect and process the following personal data about You:

• Information and documentation that You as a Customer or Partner provide by filling in the JOIN NOW form or the Contact Us form available at our website https://www.1d3.com. Such information may include Your name, surname, Your in-game name, Your e-mail address, telephone number, Your website, Your age, a unique number/ identifier in connection with Your account, and the name of Your company, and other account data and information which You provide;
• Where You as a Customer or Partner have been granted access to the 1D3 System/ Account – content information, game data and patterns that You as a Customer provide to us when You register for and use our products, make a purchase, e.g. game forums, chats or when You provide feedback about our products. Such information may include Your name, e-mail address, information about the purchased product, payment instrument and transaction data, which will only be submitted directly to the payment service provider under secure protocols, Your game preferences, details of Your visits, including, but not limited to, location data, weblogs and other communication data when You request information or support from us, and the resources that are accessed by You, information that You post, comment, share or like in any of the games-related forums operated by 1D3, information sent through in-game chats, information other than the account data You provide us when participating in competitions, contests, loyalty programs, tournaments, responding to surveys;
• Information and documentation that You as a Partner provide to us in order to conclude an agreement. Such information may include Your name, country, telephone number, e-mail address, company name, current job position;
• Information and documentation that You as a Visitor provide to us during the process of applying for a job vacancy. Such information may include Your name, date of birth, home address, country, telephone number, e-mail address, company name, current position, previous places of employment, education and other information which You provide;
  A record of correspondence / communication and/or the telephone call in the event You contact us. Such record may include Your name, surname, e-mail address, telephone number, name of Your company and other personal data You may disclose to us during such communication;
• Information about You as a Partner, which we receive from other sources and third parties, including, but not limited to, our business partners, payment partners, co-promotion partners, advertising partners, service providers and subcontractors, game developers and game platforms, public authorities and auditors, credit reference agencies, and other third parties, as well as publicly available information;
• We may also collect certain data (like IP address, username, etc.) that is required for our detection, investigation and prevention of cheating in the game and End-User Licence Agreement violations.

Other data:

We may also collect non-personal information about You through Your interaction with and use of our games and other products, which does not identify You as a specific individual. Such non-personal information that we may collect includes:

• Browser and device data (both software and hardware), for instance, IP address, operating system and browser type, data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information. This is statistical data about our website users’ browsing actions and patterns and does not identify any individual;
• Tracking data and Cookie data, such as time spent on 1D3 website, pages visited, language preferences, and other anonymous traffic data;
• Partner data, such as a company’s name, product and service offerings, jurisdiction.

How we use personal data

We use Your personal data in order to provide our services/products to You, in the capacity of a Customer or Partner, and to respectively conclude contracts and carry out our contractual obligations. In this regard, we rely on a contract entered into by You and 1D3 as the valid ground for the processing of Your personal data.

We may also use Your personal data to improve the content and features of our website. In this regard, we rely on the legitimate interests pursued by us.

In addition, we process personal data in order to carry out various marketing activities and in this regard, we rely on Your consent as the valid ground for the processing of Your personal data.

Examples of how we may use Your personal data include:

• to provide You with information, products or services requested from us, i.e., allow You to install games, operate the products, verify and confirm Your payments;
• to provide You with information, in-game offers which we feel may interest You, provided that You have consented to be contacted for such purposes;
• to notify You about features of our website, changes or updates to our products or services, or changes to our policies;
• to ensure that content from our website is presented in the most effective manner and to keep our website safe and secure;
• to allow You to use interactive features of our website;
  to administer our website;
• to fix crashes and other technical issues that may arise while You are installing games, operating products or services;
• to respond to Your inquiries and provide customer support, communicate with You and about Your account or transactions;
• to improve our products and services in order to make them more suitable and interesting for You and our players in general;
• to conduct market research and carry out marketing activities;
• to detect, investigate and prevent You from cheating in the game and/or violating End-User Licence Agreement and particular game rules and policies.

How long we will keep your personal data

We will store Your personal data for the period necessary to fulfil the purposes listed above, unless a longer retention period is required or permitted by law. Please be aware that we may be required to retain Your personal data for various technical and legal reasons. This means that in the event where You cease to make use of our services, we will still retain certain personal data in order to carry out our legal obligations.

Use of services by minors

We recognise that we have a special obligation to protect personal information obtained from children. We do not knowingly collect personal Data from any child, or process such information, without parental consent. In general, children may access the 1D3 services only if 1D3 has obtained prior verifiable parental consent from their parent or guardian in compliance with the applicable data protection and security laws.

If you are a parent or guardian, please discuss this Privacy Policy, End-User Licence Agreement and Website Terms of Use with your children so that they have a full understanding of the information they may be asked to provide when using the 1D3 services. If you have any questions on the subject of how we treat children's information, do not hesitate to contact us via dpo@1d3.com

How we disclose personal data

We may share information about You with certain third parties, as described below, and as otherwise described in this Privacy Policy. We do not sell or otherwise share personal information about You, except as described in this Privacy Policy.

In certain circumstances we may disclose the personal data we have gathered about You to the following categories of recipients:

• Our group companies. In order to provide our services/products, we share personal data with our group companies. 1D3 is the entity responsible for the general use of personal data by other group companies in relation to the services/products provided by 1D3. Our group companies are responsible for the use of personal data in relation to the services provided respectively by them.
• Third-party service providers. We disclose personal data to service providers or agents working on our behalf for the purposes described in this Privacy Policy only when it is necessary to ensure the provision of our services. For instance, such third-party service providers include payment service providers, companies assisting us with protecting and securing our systems or products. Any service provider or agent that we retain must comply with our data privacy and security requirements.
• Third-parties in relation to transfer of business. For instance, if we sell any business or assets or merge with another business entity, it may be necessary to disclose personal data to the prospective business owners or partners.
• Third-parties in relation to a legal obligation or if we are permitted to do so by law. In certain circumstances we may be under an obligation to disclose or share Your personal data with auditors, regulatory authorities or law enforcement bodies in order to comply with a legal obligation. We may also disclose personal data, if it is permitted by law, in order to enforce or apply the Website Terms of Use or other agreements or to protect our rights, property, customers or others.

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Your personal data may be transferred to and processed at a destination outside the European Economic Area (hereinafter – “EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our service providers. Where such transfers of personal data take place, we have concluded either Standard Contractual Clauses or other appropriate safeguards, in order to ensure that Your personal data is treated in a secure manner and in line with this Privacy Policy.

Your rights

You have certain rights in respect to the way we treat Your personal data:

• You are entitled to access Your personal data and receive information regarding Your personal data that we process. You can do so by either signing in to Your Account or by contacting us at dpo@1d3.com;
• You are entitled to rectify the information we have about You if it is inaccurate. You can do so by either signing in to Your Account or by contacting us at dpo@1d3.com;
  You are entitled to object to the processing of Your personal data;
• You have the right to revoke Your consent for processing of Your personal data for the marketing purposes. We will inform You (before collecting Your data) if we intend to use Your data for such purposes or if we intend to disclose Your information to any third party for such purposes;
• You may also request us to erase Your personal data or cease the processing of Your personal data. However, please note that this right may be subject to certain exemptions. Namely, in situations, where we are under a legal obligation to retain Your personal data, we will not be able to fulfil Your request and, in such an event, we will inform You accordingly;
• You may also request us to provide Your personal data to You or transmit it directly to another controller and we will comply with such request, provided that the personal data processing previously carried out by us was based on Your consent or was necessary for the performance of a contract and where it is technically feasible;
• You have the right to lodge a complaint to the Data Protection Inspectorate if You believe that we have not complied with the requirements of the General Data Protection Regulation with regard to Your personal data.

Cookies

The 1D3 website uses cookies, which are text files placed on your computer, to help us analyse how users use our products and to distinguish You and Your device from other Visitors of our website. This helps to provide You with a good experience, while browsing our website, to improve marketing, analytics and also allows us to improve our website functionality.

The use of cookies is standard on the internet. You may adjust Your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to You. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if You do this, You may not be able to access the full functionality of our website.

For more information, please see our Cookie Policy.

Security

All information provided by You to us is stored on secure servers and we use appropriate organisational, technical and administrative measures to protect Your personal data. Once Your information is received, we use strict procedures and security features to prevent any unauthorised access, loss, theft, misuse, disclosure, alteration and destruction.

However, please note that no transmission of information via the internet is completely secure and no storage system is guaranteed to be entirely secure. If You have any reason to believe that Your interaction with us is no longer secure, please contact us immediately.

Changes to the privacy policy

We may change or update this Privacy Policy. Any changes we may make to this Privacy Policy in the future will be posted on our website and any such changes will be effective starting from the date when we post the revised Privacy Policy.

We may provide You with notifications regarding the changes in the Privacy Policy by posting them on our website.

Data protection officer

We have appointed a data protection officer, whom You may contact, should You have any questions or concerns regarding our personal data processing practices. Our data protection officer’s contact information is as follows: dpo@1d3.com.

Contact

If You wish to contact us regarding this Privacy Policy, please use the e-mail address dpo@1d3.com or the following address: 1D3 DIGITECH OÜ, Harju county, Tallinn, Kesklinna district, Tornimäe tn 7-26, 10145.

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