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PRIVACY POLICY

These are the terms of service (the “Terms”) of Aftermath Interactive AB, with company number 556930-7829, with registered address at Gamleväg 9c, 23631 Höllviken, Sweden, (“AI”, “we” or “us”).

The Policy describes how we collect and use information, including personal data, about you (“User” or “you”) on our websites such as aftermathplay.com and handsofvictory.com or when you play any AI game such as Hands of Victory or other future games (each a “Game” and together the “Games”) whether accessed via web browser, social networking sites (for example, Facebook) or as apps via platforms (for example, Apple’s ‘App Store’, Google Play). If you have any queries about this Policy, please contact Aftermath Interactive at contact@aftermathplay.com

SUMMARY

When you play our Games we will get and store some personal data about you that we will use for different purposes as explained in this Policy. Most of that data is necessary for us to provide Games to you and for you to play our Games.

However, in some cases we may ask you to provide us with other personal data or use personal data for purposes that are not necessary to play our Games. In those cases, you do not have to provide that personal data to us or have the right to opt out from such use (if the same type of data is used also for other purposes). An example of this is that we may ask you for your email address for password retrieval. We will also never use that email address for any other purposes unless we explicitly inform you in advance and provide you the right to opt out or ask for your consent as applicable.

Our games, at this time, DO NOT use your data to present you with targeted ads.

You have the right to object to how we use your personal data and you also have other rights to gain insight into and influence how we use your personal data. These rights include that:

– You can ask for the personal data we have about you;
– You can ask that we correct any incorrect data we have about you;
– You can ask us to delete personal data we have about you;
– If you have any concerns with how we treat your personal data, you can file a complaint with the supervisory authorities;

Please note that AI will have no possibility to know if you delete a Game from your device and your personal data will thus be stored by us even if you delete a Game. If you want to request the data we have about you or want us to delete personal data we have about you.

These are examples of personal data that AI will collect when you use the Games:

Data related to your device (such as your IP-address, device identifier and advertising ID). We use this data for example to be able to provide the Games to you .

Contact and sign in details (your username, password and email). In some of our Games, you can provide a username and password. If you play one of those Games we will store this information. The purpose is to allow you to sign in to your account on multiple devices and to make it possible for you to retrieve your password if you forget it. 

Information regarding your purchases within the Games. When you make a purchase in our Games, we will store a log of that purchase. The purpose is to fulfill regulatory requirements as well as to assist customer support if there are any problems with a purchase you have made. 

Gaming history
When you play one of our Games we will save information about what Games you played, general activities in the Game and for how long you played that Game. This information is used for data analysis of how the Game works and to be enable us to improve the Game.

 Facebook information.
If one of our games permit access to the Game through Facebook and your privacy features on Facebook allow it, AI is able to access certain information about you through Facebook. If you do not want us to collect this information please do not sign into any Game through Facebook. 

Other information provided to customer service (information you choose to provide when contacting us for technical or other support).

Information provided in a chat function:
In some Games we provide a chat functionality. We will process and store any personal data that you provide in the chat. If you do not want us to collect this information, please do not use the chat functionality in these Games.

Please note that you should never submit any personal data related to anyone else in any such chat and must in particular not submit any data that is related to health, sexual orientation, race or ethnicity, political or religious beliefs or membership in any trade union. 

Please report to us if you encounter any chat messages in breach of this rule. We will delete any chats that we consider to be in breach of this rule or that may be defamatory or otherwise illegal or inappropriate, as decided in our sole discretion.

Your personal data will be transferred to companies outside the EU that we have engaged to provide services to us. The relevant countries’ legislation may not ensure the same level of protection for personal data as where you live.

Below follows a more detailed description on how we use personal data.

WHO THIS POLICY APPLIES TO

This Policy applies to everyone who uses the Games or who otherwise may come in contact with us for example by email or telephone or our websites, such as AI.com.

WHEN THIS POLICY APPLIES

This Policy applies to AI’s processing of personal data. The term “personal data” is any piece of information that, either on its own or together with any other pieces of information, can be used to identify a living individual, and any other data that qualifies as personal data in accordance with the law applicable to AI, including the General Data Protection Regulation (the “GDPR”).

WHAT LEGAL GROUNDS DO WE RELY ON WHEN PROCESSING YOUR PERSONAL DATA?

AI can only use Personal Data if there is a legally valid ground to support the relevant use. AI relies on the following legal grounds:

Performance of a contract:
We rely on this legal ground when the use of personal data is necessary for AI to be able to deliver a Game or other product or service that a User has requested such as to enable the User to sign into its account, play the Games, improve your player experience of the Games, including to adjust the difficulty of a Game based on your progress, to make it possible for you to play against other Users or as part of a Team, complete your transactions in respect of your purchases within the Games and to receive help from AI’s customer service.

Legitimate interest:
Certain types of use of Personal Data are based on what AI considers to be a legitimate interest for AI to use the personal data. We rely on this legal ground for example to improve our Games, to show personalized advertisements and to prevent fraud and other illegal activities. A requirement for AI to rely on this legal ground is that such a legitimate interest is not overridden by the interests, fundamental rights or freedoms of the Users and the Users have the right to object to the relevant use. You may contact us at any time to request more information on how we have reached the conclusion that our use of personal data that is based on a legitimate interest is not overridden by your interests.

Legal obligation:
We rely on this ground when we must process personal data to comply with a legal obligation applicable to AI, e.g. financial information that needs to be stored for bookkeeping- and financial reporting purposes.

Consent:
When we have asked for your consent to certain types of processing, and you have agreed to provide your consent, we will use your Personal Data for the use of data that you have consented to, for example if we have asked to use your email for any purpose that requires consent. You can at any time revoke your consent and we will then cease any future use of your Personal Data that is based on such consent.

WHAT ARE YOUR RIGHTS?

Right to object: 
You are entitled to object to processing of personal data that we base on our legitimate interest on grounds relating to your particular situation. If you lodge an objection, and the processing is based on a legitimate interest, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that overrides your privacy interest.

You can always also object to us sending you direct marketing or that we use personal data for profiling related to direct marketing, and we will then stop such use. You can also opt out from personalized advertisements that are based on your profile.

However, please note that even if you object to certain processing, AI may still continue such processing if it is based on another legal ground, for example to provide the Games to you (should you still want to use them) or to fulfil legal obligations.

Right to restrict: 
You can request that our use of certain personal data is restricted, for example, if the personal data is not correct or if you believe that AI does no longer need the personal data for the purposes as set out in this Policy or if you have objected to our use of personal data that is based on a legitimate interest.

Right to access and rectification<:
 Upon your request, we will inform you in more detail of how we use your personal data. The information that you are entitled to receive include what personal data AI processes regarding you, from where we have collected the data, for what purposes the data has been used. AI may charge a reasonable administrative fee for repetitive requests. If a request is manifestly unfounded or excessive, in particular because of its repetitive character, AI may also refuse to act on the request. We may also ask you to specify what information that you want to access.

You have also the right to, at any time, request a correction of any inaccurate or incomplete personal data.

Right to be forgotten: 
You can request us to erase your personal data, for example if you have terminated an account with us and the personal data is no longer necessary in relation to the purposes for which it was collected, you withdraw your consent and there is no other legal ground for processing or you object to our use of your data that is based on a legitimate interest. Your personal data can be erased also in other circumstances. Please contact AI to receive further information on erasure of your personal data.

Right to withdraw consent: 
If you have provided a consent to AI for processing of personal data, you can always withdraw such consent for any future processing that is based on such consent.

Right to data portability: 
You have the right to receive the personal data concerning you, which you have provided to us and that we use based on your consent or to perform a contract with you, in a commonly used and machine-readable format and to have this information provided to another controller, where this is technically possible.

Accessing your data or Request to be forgotten: 
If you want to access or want us to delete data we have about you, you can do so in the privacy section of the preferences of a Game.

Note: Not all Games have implemented this feature. If a certain Game does not have this privacy section, please download one of the Games that do, e.g. Backpacker or Word Memories to make use of these rights. If you need help with how to do that, please contact customer support. When you request access to your information, you will get the personal information that we have about you concerning all of our Games.

When you request to be forgotten, we will remove all personal information we have about you in all our Games. This means that you may lose progress and purchases in all Games made by us and we will not be able to restore this.

For all other inquiries please contact customer support.

Our games, at this time, DO NOT use your data to present you with targeted or any other ads.

FOR HOW LONG WILL PERSONAL DATA BE STORED?

For now, it is not appliable for AI to have a fixed time limit for how long your user data will be stored. This is because we always want you to be able to restore your game session at a later time. If however a game will be discontinued, all data related to that game will be removed, this includes your personal data. You can at any time contact us to receive more information on how long we store personal data.

WITH WHOM WILL PERSONAL DATA BE SHARED?

Partner companies: Your personal data will be transferred to and processed by publishers, third party providers and suppliers which perform services for AI (data processors). Such companies will be located both within and outside the EU.

Third Parties: 
All third party providers and suppliers must follow AI’s instructions and when applicable, written data processor agreements and any other agreements that are in place between AI and its third party publishers/providers/suppliers, and must implement appropriate technical and organizational measures for the protection of the personal data.

The third parties can be grouped into:
Core infrastructure: 
We employ the use of 3rd party servers. Websites are hosted with Flywheel and game server are hosted by No Ack hosting. Your personal data will be stored with the server provider, either within EU or in the United States.

Customer Support: 
We use Zendesk to handle customer support cases for some of our apps, so if you contact customer support, personnel from either of these companies will see your support case. Zendesk complies with GDPR.  

Marketing partnerships:  
We use MailChimp/Mandrill to send transactional emails. These are sent to you on events like registration confirmation to game and in some game events. Is controlled by accepting or not accepting mails at registration. Your registered email and statistics of mails sent are kept with Mandrill.

Marketing emails are sent to update you on the content of new releases, new purchasing opportunities or new special events. You can choose to accept or not accept these marketing e-emails at registration. If you accept you can rescind that acceptance at anytime via a link in previously sent marketing e-mails.
MailChimp/Mandrill complies with GDPR's data transfer policies under the Privacy Shield Certification.

Authorities:
 AI may need to provide personal data to relevant authorities (e.g. tax authorities or the police) in accordance with applicable law and in order to fulfill legal mandatory obligations in each jurisdiction where AI operates to the extent allowed under applicable data protection law. In the event of data breaches, certain personal data may need to be provided to the relevant data protection authorities.

In addition, if you link to the Games from a third party site or via a social network (e.g. Twitter, Facebook), AI is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

TO WHAT COUNTRIES WILL PERSONAL DATA BE TRANSFERRED?

Your personal data will be transferred to companies in other countries both within and outside the EU that we have engaged to, among other things, be able to provide Games to you and to allow you to play our Games. The relevant countries outside the EU may not ensure the same level of protection for personal data as your country. In such cases, AI will ensure that the personal data is adequately protected by the receiving parties in such countries. Adequate protection may typically be to impose on the receiving party contractual obligations in accordance with model clauses that have been approved by the European Commission that ensure that such party maintains the same high level of privacy and data security as practiced by AI. You will find more information here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Security: 
AI has implemented technology and policies to safeguard your privacy and personal data from unauthorized access and improper use. All communication between game servers and the games are safe and encrypted using SSL. To secure your data, only a few people at AI have access to the user data. These people are well educated in handling personal data. Also, we do not aim to collect information about you which makes it possible for us to identify you directly, however in some games you must provide your name, email address or username.

Children: 
You need to be 18 or older to play our Games or use our services.

WHAT SHOULD YOU DO IF YOU HAVE ANY COMPLAINTS?

If you have any complaints on how we use your personal data, or would like further information, we would ask you to first contact us using the contact details set forth below or the functionality for contacting us as provided in our Games.

CONTACT DETAILS

If at any time you would like to contact AI about your views on this Policy or any enquiry relating to your personal information or for any matters referred to in this Policy, you can do so by sending an e-mail to us at contact@aftermathplay.com

UPDATES

This Personal Data Policy may be modified by AI at any time. Notice of any such modifications will be provided on AI’s website or through popups in our Games.