2018-05-23
General
imitera AB (“we” or “imitera”) cares about your privacy. Therefore, we always strive to protect your personal data in the best possible way and to comply with all applicable laws and regulations for the protection of personal data. In this policy, we want to inform you about how we collect and process your personal data.
This policy applies to any personal data we process when you download, access and/or play the game Magic Chess, whether on your PC, on a mobile device, on our website www.imitera.com (the “Website”) or any other website, device or platform.
This policy also applies to personal data that we have received about you from someone playing Magic Chess, even though you are not playing Magic Chess yourself. This could be the case, for instance, if a Magic Chess player in your surroundings use the augmented reality function in Magic Chess.
This policy is made available via our Website, the app store or platform that you download Magic Chess from (such as the Apple App Store and Google Play Store) and on any website or platform where you can play Magic Chess.
Please note that Magic Chess is not directed to children under the age of 13 and that we do not knowingly collect personal data from children under age 13. If we learn that we have collected personal data of a child under the age of 13 we will take steps to delete such information as soon as possible.
Who is responsible for your personal data?
imitera AB, company registration number witheld, with address Norgegatan 2, 164 40 Stockholm, Sweden telephone number +46 (0)761 66 33 45 and e-mail address info@imitera.com is responsible for the processing of your personal data (the controller).
What personal data do we process?
The personal data that we process is the data that you have provided us with or that we collect from you when you download, access and/or play Magic Chess. We may also process certain personal data that we have received from a third party, such as someone else who is playing Magic Chess.
Personal data that you have provided to us: When you download, access and/or play Magic Chess you provide certain information about yourself to us. You also provide us with certain information about yourself when you register a Magic Chess user account. You may also provide us with personal data for other reasons. The personal data that you submit to us can be, for instance, your user account details, name, contact details and e-mail address information, age, gender, information from a social network, credit card number and/or bank account number.
Personal data that we have collected from you or a third party: When you download, access and/or play Magic Chess we will automatically collect information about your device ID as well as your IP address. This is done by default and will be done regardless if you have registered a Magic Chess user account or not. If you make in-game purchases, we will process data regarding your purchase and your purchase history. We may also process personal data about you such as picture frames depicting you when you are playing Magic Chess or if you are in the surroundings when someone playing Magic Chess uses the augmented reality function.
For what purposes do we process your personal data?
All collection and processing of personal data are for the purpose to administrate and fulfill our obligations to you as a Magic Chess player, improve Magic Chess and your gaming experience and to comply with all applicable laws, regulations and decisions made by public authorities.
For more information about the purposes for which we process your personal data, see below.
Providing the game to your device
We process your device ID and IP address in order for us to be able to provide you with the right version of Magic Chess as well as to be able to conduct trouble-shooting and make optimizations and updates of Magic Chess. If you use several different devices, we will process information about each device’s device ID. The legal basis for our processing is that it is necessary for us to process this data, otherwise Magic Chess cannot be used on your device or function the way it should.
Administration of your user account
If you have voluntarily chosen to register a Magic Chess user account we will process additional information which you choose to provide us with such as your name, your contact details and e-mail address, your age, your gender, your credit card number, your bank account number or your PayPal user information such as username and e-mail.. The personal data is processed in order for us to administrate your user account and to facilitate your use of Magic Chess, including making it possible for you to make purchases in the game and to make withdrawals from your user account. If you have a user account we will also process information about your purchase history in order for you to keep track of your previous purchases and for us to make sure that you have received what you have purchased from us. Your credit card number will only be processed by trusted third parties as described below and will never be stored by us. The legal basis for our processing is that it is necessary if you want to register a user account and/or to use all functions in the full version of Magic Chess or your consent if you have chosen to give us specific information, such as for example your gender. If you don’t provide us with all the information we need in order to register a user account, you won’t be able to have a user account and/or to use all functions in the full version of Magic Chess. If you don’t provide us with the information that is voluntary to provide us with you may not be able to use certain functions or receive certain information based on such data.
Interaction with social network
If you agree to allow Magic Chess to interact with a social network, we will process your email address and any other personal information which that social network shares with us that will allow us to personally identify you and to help your contacts on that network find you so that you can play socially. If you allow Magic Chess to interact with a social network, you can invite your friends to play Magic Chess and compete with them as well as see an updated score board which shows the current results of you and your friends. The information the social network shares with us can consist of your gender, age, country of residence and/or contact list. The legal basis of this is your consent. If you don’t give your consent to this, you cannot allow Magic Chess interact with a social network.
Augmented reality
On camera-equipped mobile devices you may access and/or use a mixed reality (MR) or an augmented reality (AR) function to improve your gaming experience of Magic Chess. When using the MR/AR function, we may process personal data about you and/or other persons in your surroundings by temporarily storing real time images which are captured by you when you use the MR/AR function on your mobile device. We will not store any such personal data or use the camera or personal data for any other purpose than for providing you the MR/AR function in real time. If you use the MR/AR function on a mobile device, we may process real time images of you and/or persons in your surroundings. The legal basis for our processing of real time images of you as a player is that the processing is necessary for us to process this data if you want to use the MR/AR function, otherwise the MR/AR function could not be used by you. The legal basis for our processing of real time images of you as a person in the surroundings of someone playing Magic Chess who is using the AR function is our legitimate interest of being able to offer the MR/AR function in Magic Chess to Magic Chess players.
Administration of in-game purchases
To be able to administrate any in-game purchases and to fulfill our obligations to you after you have made a purchase we may process information about your purchase, if applicable, your user account and credit card information or other payment information such as transaction ID if you pay with PayPal. The legal basis for our processing is that the processing is necessary for us in order to fulfill our contract with you as regards to giving you the possibility to use the specific payment solution you have chosen and which requires such information. If the data is not provided it is not possible for you to make purchases in Magic Chess with the chosen payment solution.
If you make purchases via a third party provider such as Google Play, App Store or Steam your payment information will not be processed by us at all since the third party provider, not imitera, will be the data controller of the processing of that personal data.
Marketing purposes etc.
Since we want you to continue to play Magic Chess, we will for a period of one year from the last time you played Magic Chess, be using your e-mail address to send you newsletters and special offers by e-mail. The legal basis for our processing of these personal data for the purpose of sending newsletters is our legitimate interest to communicate with you as a former Magic Chess player for marketing purposes.
Statistics, surveys and business development
We may use your personal data such as your e-mail address, gender, age, player history and/or purchase history for customer surveys, business development and for statistical purposes. The legal basis for our processing of this personal data for the purpose of conducting customer surveys, for compiling statistics and/or to develop our business is our legitimate interest to get information about your experience of Magic Chess and how to improve and develop the game and our business. For the purpose of improving Magic Chess we may also process your personal data when analyzing different player segments.
Who can gain access to your personal data?
As a starting point, your data will only be processed by imitera and relevant companies in the imitera group. We may also share your information with our selected partners and suppliers in accordance with below.
- For payment of in game purchases we may share information about your credit card number or PayPal information to the payment processor you have chosen for your purchase such as DIBS or PayPal. If you have chosen to withdraw money from Magic Chess to your PayPal account we will share your PayPal information with PayPal.
- For the purpose of inviting your friends to Magic Chess or other interactions with social networks we may share information about your Magic Chess user account name and score board with social networks.
- Our internal and external IT suppliers and any other suppliers we hire may get access to all the personal data we handle about you, but only to the extent necessary in order to fulfill their obligations in relation to imitera.
Transfer of personal data
imitera, imitera group companies and imitera’s partners and suppliers will, as a main rule, only process your personal data within the EEA. In the event that the data is processed outside the EEA, the processing is carried out solely in accordance with applicable data protection legislation.
For how long will we store your personal data?
Personal data that we process in order to administrate or to fulfill our obligations to you under the agreement will not be stored for longer than is necessary for us fulfill our obligations. Real time images which are processed when you or someone playing Magic Chess are using the MR/AR function in Magic Chess will only be processed in real time and thereafter immediately deleted.
For the purpose of bookkeeping, we store, in accordance with applicable accounting legislation, information about our agreement with you for seven years.
In accordance with applicable legislation, we are entitled to process your contact information for direct marketing purposes for a period of time after you have made a purchase in Magic Chess or since you began being inactive. imitera may therefore store your contact information in order to send direct marketing to you during the time we have the right to do so in accordance with current data protection legislation, marketing legislation and practice.
For you who have registered an account with us, we will process all your personal data until you unregister your account with us or ask us to delete certain data. However, we always erase your account if you have been inactive for two years. Purchase history is sorted out in any event at the latest after two years after the purchase.
Personal data which we process with your consent as legal basis, such as information about your gender or information which we have received from the social network you have allowed Magic Chess to interact with, will be processed until you withdraw your consent or until you unregister your account with us (whichever occurs first).
Your personal data may be stored longer than the above, to the extent we are required to do so by law, regulation or decisions made by authorities.
How can you affect our processing of your personal data?
At any given time, you have the right to withdraw all or part of a given consent on the processing of personal data. The withdrawal of consent may, however, have no effect on our processing of your personal data for the period prior to the recall took place. You also have the right, at any time, to object to the processing of your personal data for direct marketing.
In accordance with applicable data protection legislation, you have the right to gain access to information about the personal data we process about you and the right to request correction of your personal data. If you want this information or wish to correct your personal data, you can request us to do so by contacting us by mail or e-mail. Our contact details are stated above.
You have, under certain circumstances, the right to request the deletion or restriction of your personal data or object to our processing. You also have the right to submit a complaint to the Swedish Data Protection Authority or other supervisory authority who is supervising companies’ handling of personal data.
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