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ActaLogic Privacy Policy

Introduction

ActaLogic (hereafter “We” or “our”) considers the protection of your personal information and data (hereafter “Data” or “your Data”) and the respect of your privacy to be of crucial importance. In this privacy policy you will find all the relevant and transparent information regarding collection, usage, sharing, transfer and protection of your Data in relation to the use of our games, products and services. This privacy policy was last updated on November 10, 2021.

Data controller

ActaLogic d.o.o., registered in Slovenia, headquartered at Cesta 24. junija 23, 1231 Ljubljana - Črnuče, Slovenia, is the data controller of your Data as further described in this document.

Basic information

We collect some of your Data through our video games and/or website, to allow you to sign-up to our newsletter, forum, and competitions, to take part in testing our games, to receive promotional and commercial offers if you have given your consent and to apply to our job and internship offers.

We mostly collect identification data and information regarding your use of our services (your email address, your name, your pseudonym, your password, your IP address). The categories of information that we collect in connection with your use of our games, products and services, as well as the related purposes and legal bases, are described in the data processing table below.
You have right of access, rectification and deletion of your Data, the right to limit their processing, right to object to the processing, and right to portability. You can exercise these rights at any time by contacting our Data Protection Officer (DPO) at the following address: privacy@actalogic.com. If after having contacted us you feel your data protection rights have not been respected, you have the right to lodge a claim with the competent supervisory authority. When the processing of your data is based on your consent, you have the right to withdraw your consent at any time.

Minors

Only minors of 15 years and older are allowed to subscribe to and use ActaLogic products and services. ActaLogic does not intentionally collect personal data from minors aged under 15 or under minimum equivalent age depending on the jurisdiction concerned. If we realize we have collected personal data regarding a minor within the meaning of the applicable data protection regulation, we will immediately delete any personal information regarding the minor in question.

Contact

If you have any questions, concerns or claims regarding this policy or the processing of your Data, you can contact us by sending an email to our Data Protection Officer (DPO) at the following address: privacy@actalogic.com, or by mail at our headquarter address.

Data collected

We collect certain Data through our video games or website to offer you the best possible experience when using our products and services, and also for marketing purposes, but only with your prior consent. We mostly collect identification and usage/telemetry data.
When recruiting our staff, we only collect information relating to the professional profile that the candidate wishes to share with us.
We only collect Data strictly necessary for our games, services related to our games or strictly necessary for our staff recruitment procedure.

How is your Data collected

Your Data is collected directly, when you sign up to the newsletter, to the forum, to the competitions or to the testing of our games (playtests) or you apply for one of the jobs proposed on our website.

Indirectly the Data are collected via the use of cookies and other trackers, third-party distributors and partners when you have expressly consented to giving your email address for commercial purposes, reception of newsletters and promotional materials, via our staff recruitment providers and also when you access or use our games and services available on social networks or other third-party platforms and websites.

Please note that this policy does not apply to data processing implemented by Third-Party Websites, and that we do not control their respective data privacy practices. We recommend that you take careful note of the privacy policies available on each Third-Party Website, particularly the provisions relating to the sharing your Data.
ActaLogic will process any Data received indirectly according to the conditions set out under this General Personal Data Protection Policy.

How is your Data processed

Type of processing Data Purpose Legal basis
Online services Email address, password. To create and manage your account and customer services, to provide the services you have signed up to according to the End User License Agreement that you have accepted and to provide and give access to features and extra content that you have requested (Mods, etc.) Necessary for the performance of the End User License Agreement.
Forum email address, username/alias, password
Optional: Full name, age, website, address, description
To sign up and interact with the forum Necessary to carry out the services relating to the forum according to the terms and conditions you have accepted.
Playtests Full name, date of birth(age), identity photo, email address, country, username/alias To sign up to and take part in testing phases of video games published by ActaLogic and to ensure the correct execution of testing phases. Necessary for the performance of the testing phase participation contract and to comply with our legal obligation not to process information concerning minors without consent or parental authorization.
Marketing Email address
Optional: Full name, country, date of birth(age)
To send you special offers, promotional and commercial materials concerning products and services offered by ActaLogic or third-party partners. Your consent*
Statistical analysis and Security Information regarding your use of our services To ensure and verify the efficiency and availability of the provided services, to generate statistical data regarding the user of our services, to carry out surveys and analysis allowing us to improve our services and to ensure the security of ActaLogic information systems. Our legitimate interests to verify and correct issues relating to provided services, and regularly improve the services, to develop new features, products and services and to maintain an appropriate security level for ActaLogic information systems.
In-game technology tools Demographic data (language, state, city, GPS data), logs (connection details, login, IP address), technical specifications about the operating system, the device used in connection with our games, the mobile operator and the internet service provider, gaming data (Telemetry). To enhance our game, your gaming experience and our online services and to provide technical support. Necessary for the performance of the End User License Agreement. Unity Privacy Policy
Cookies Personal data obtained via cookie configuration: in particular, a cookie’s unique identifier, IP address, terminal identifier, network types, country and language preferences, etc. To customize your experience, to better understand your usage, your interests and preferences, to improve website, the application or the game performances, and to provide you with a technical support. Your consent given through the cookie management solution displayed when accessing the website or the application.
Applications / recruitment Identification data (full name, address, date and place of birth), professional experience and qualification data, and information provided in the Candidate’s CV. To assess and evaluate the candidate’s suitability for the proposed job and to manage the collection and processing of job applications. Our legitimate interest to reinforce our staff and implement our recruitment policy.

* You can withdraw your consent for reception of commercial/marketing communications by ActaLogic or our partners at any time by clicking on the “Unsubscribe” link provided in each email, or by contacting us according to the procedure described in this policy.

Data sharing

Communication of your Data with our providers and suppliers:
As a video game developer, we can communicate or share some collected Data with our partner development studios, publishers, our IT providers, our recruitment agencies and providers, and our suppliers acting as subcontractors for technical and operational purposes to allow us to offer you quality games, to provide you with requested services, or to ensure effective recruitment. We set up the contractual and organizational measures necessary so that the processing of your Data by these third-party providers is strictly limited to the purposes defined in this policy, and to ensure the confidentiality and security of your Data.

Communication of your Data with our commercial partners:
Subject to your prior consent obtained on the sign-up page of the website, we share your email address with trusted partners whose identity will be specifically mentioned on the consent form, so they can send you promotional offers and other marketing materials. Please note that this policy does not apply to data processing by these trusted partners, acting as independent data controllers. We recommend that you take careful note of the privacy policies of these trusted partners.

Your rights

You have all of the following rights over the Data we collect and process:

  • Right to request modification, update or rectification of your Data when you consider it is wrong, inaccurate or incomplete.
  • Right to access your Data: you have the right to obtain confirmation that your Data is or isn’t processed, when it has been processed, the right to obtain access to this Data, and a copy of any Data processed by ActaLogic.
  • Right to request deletion of your Data for reasons provided by the applicable law and particularly when:
    • The personal Data is no longer necessary to the purposes for which it was collected or processed
    • You withdraw your consent on which the processing was based, and there is no other legal basis for the processing
    • You object to the processing of the Data and there is no legitimate and compelling grounds for the processing
    • You consider your Data has been unlawfully processed
    • Your Data must be deleted to comply with a legal obligation
  • Right to limit the processing of your Data, for reasons set out under the applicable legislation, notably when:
    • You challenge the accuracy of your Data
    • You consider the processing unlawful and you object to the deletion of your Data
    • The Data is still necessary for establishment, exercise and defense of legal claims, whether ActaLogic still needs the Data or not
  • Right to object to the processing of your Data if we use your Data:
    • For the performance of a task carried out for reasons of public interest
    • For our legitimate interests
    • For scientific or historical research purposes, or for statistical purposes
    • For commercial and marketing purposes
  • Right to withdraw consent at any time when the Data processing is based on your consent (note that this withdrawal does not affect the lawfulness of the processing based on consent before its withdrawal).
  • Right of Data portability: this right applies to Data you have provided to us when the Processing is automated and based on your consent, or carried out on the basis of the performance of a contract. You have the right to ask us, if it is technically feasible, to transfer your Data to a third-party or to provide them directly in an accessible and machine-readable manner.
  • Right to transfer instructions concerning storage and communication of your Data after your death.
  • Right to lodge a complaint with the competent supervisory authority if you consider we do not respect our obligations with regard to your Data.


To exercise your rights, you can send your request mentioning the relevant right(s) and the reasons, if necessary, by sending an email to our Data Protection Officer (DPO) at the following address; privacy@actalogic.com, and/or by mail at our headquarter address.

We will assess and determine the admissibility of the request within one month after receipt. Assuming the request is admissible, we will provide the requested information or carry out the actions relevant to the rights cited in the aforementioned period. If, in view of the complexity of the request or the number of simultaneous requests, the delay cannot be complied with, we will inform you before the expiry of this period that our response will be postponed for up to two months. We will be entitled, if need be, not to respond to manifestly abusive requests (in particular due to their number, their repetitive or systematic nature).

How is your Data stored

Type of processing Storage Period
Online services During the usage period of our services and up to 3 years after our last contact.
Forum During the usage period of our services and up to 3 years after our last contact.
Playtests During the development period of the tested game, and up to 3 years after our last contact.
Marketing Up to 3 years after our last contact.
Statistical analysis and Security 5 years after deletion of your user account, retraction of your email address from our database, or deletion of your CV from our database.
In-game technology tools Up to 3 years after their collection, and then we will pseudonymize and archive all the data only for statistical and administrative purposes.
Cookies The cookies expire based on the set duration.
Applications / recruitment With your authorization, up to 3 years after our last contact.

Your Data is stored only as long as necessary with regard to the purposes for which it was collected, and in accordance with the applicable law. Upon expiry of this period, we will delete your Data.

How do we protect your Data

We implement and maintain all appropriate technical and organizational measures to ensure the security, confidentiality and integrity of your Data, and to protect your Data from accidental or unlawful destruction, or accidental loss, damage, modification, disclosure or unauthorized access, as well as from other forms of unlawful processing. We maintain an authentication system to protect the access to your online accounts, we use hashing procedures for some of your Data, we have a protected access to our services and servers and our employees and subcontractors of ActaLogic have restricted to an as-needed basis access to Data when providing our services, and subject to the respect of strict confidentiality obligations. We regularly perform security tests and checks and may have to temporarily suspend our services if we suspect or detect a security breach.

Transfer of personal data outside of the EEA

ActaLogic may have to transfer some of your Data out of the European Economic Area (EEA) when necessary for technical or operational reasons, to allow us to offer quality games and requested services. These transfers are made in compliance with the applicable data protection regulation and data transfer mechanisms / safeguards recognized by the GDPR. In particular, when the transfer of your Data cannot be handled on the basis of an adequacy decision by the European Commission recognizing an adequate level of protection, we will carry out other appropriate transfer and guarantee mechanisms to ensure the protection of your Data, such as with transfer agreements including standard contractual clauses as approved by the European Commission.

Hyperlinks

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites and we cannot be held responsible for the processing and confidentiality of Data provided on websites other than our own. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. Data and information transmitted via these links are under the responsibility of their editors. We therefore recommend you to be careful when browsing websites accessible via hyperlinks.

Cookies and other tracking technologies

A “cookie” is a string of information that may be transmitted to your browser by a website you connect to. They are primarily used to run some services on our website, to offer you customized content and improve our services by analyzing how you use them. Your web browser will store it for a certain period of time and send it back to the web server each time you browse the site. You can give your consent when you first visit our website via the cookies settings window.

Information about cookies used on our websites

Cookie Origin Description Duration
.AspNet.Consent Cookie consent form

Cookie which retains your preferences when placing cookies

1 year
_ga Google Analytics

Cookies used for analytics help collect data that allows services to understand how users interact with a particular service. These insights allow services both to improve content and to build better features that improve the user’s experience. Used to distinguish users.

2 years
_gid Google Analytics

Cookies used for analytics help collect data that allows services to understand how users interact with a particular service. These insights allow services both to improve content and to build better features that improve the user’s experience. Used to distinguish users.

1 day
_gat Google Analytics

Cookies used for analytics help collect data that allows services to understand how users interact with a particular service. These insights allow services both to improve content and to build better features that improve the user’s experience. Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_< id >

1 minute

Google Analytics collects aggregate visitor information such as browsing patterns and page visits to allow analysis of site performance and usage. All information collected is anonymous. See Google Privacy - Google Terms

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