Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
3. Collection of General Data and Information
The website of the REDPAD GAMES PTE. LTD. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, the REDPAD GAMES PTE. LTD. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the REDPAD GAMES PTE. LTD. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
4. Information collected
Information directly provided by you
Under this agreement, the Company collects information that you provide directly, for example, when creating accounts in the Game, secret questions and answers, making purchases or contacting the Company.
Information provided by you is collected, including:
• details of your account in the Game, including, but not limited to, your email address, username, real name, country, date of birth, phone number and password;
• secret questions and answers;
• information you provide in surveys about our Services;
• information that you provide when contacting us for help, such as your name, phone number and a description of the problems encountered (including recordings of telephone conversations);
• payment information (your name, payment card number, payment account details and delivery address);
• data on the crypto wallet provided by you for the RPGC accrual.
Information Provided While Playing Online
During your online game, the Company may collect information about your game profile, gameplay.
When you communicate using social features such as chat, the visual, audio and / or electronic information you disclose may be read, reproduced, collected, copied by other players, and may also be made publicly available. Make sure your privacy settings match your preferences.
During your participation in online multiplayer games, other users can see your in-game profile data, gameplay and statistics. In some of our games, in certain multiplayer game modes, we may record your gameplay and replay it for other players. In competitive game modes, we may record your gameplay, including your control commands, and reproduce this information along with your in-game profile and game statistics for other players, both in games and during interactive events of the Company or our partners.
Other information collected when you use our services
When using the device of our Services, we collect other information, for example, information about your device, IP address or information about the browser used.
When you use our Services, we may automatically collect other information, including:
We also collect information on your device like cookies, web storage (including HTML 5) and application data cache.
Categories of processed personal information
To the extent that these actions are applied by the applicable privacy rules, to the extent that these privacy rules apply:
We may collect additional information, for example:
If you are a recipient of a contest or lottery prize that requires tax reports, we may collect government-issued identifiers associated with you (such as a social security number).
If you participate in our competitions, we may collect identifiers associated with your government-issued documents (such as your passport number), financial information (such as bank accounts), and your health information.
If you participate in the exchange of DC for RPGC, we may collect financial information (for example, bank accounts, crypto wallet data), the recording of your image during the session, as well as other information necessary for the corresponding transaction.
5. Legal basis for data processing
Depending on your country of residence, we may rely on different legal bases when processing your information.
The legal basis for processing your personal information depends on the type of information we collect and the context in which we collect it, as well as the country of your residence specified when setting up your account or, if you are not logged in to an account, your location as determined by according to your IP address and / or the country of registration of your device.
If you reside in the European Economic Area or in a jurisdiction where similar legal requirements may apply, such as Brazil, Switzerland and the United Kingdom, we use a number of legal bases to process information about you. We process information about you if we have your consent, if there is a corresponding legal right, if processing is necessary to fulfill a contract with you and / or if we have a legal obligation to process your information. For example, we tend to be guided by:
6. How we collect information
We use a variety of technologies to deliver and measure the effectiveness of our Services, to serve ads, and to improve your gaming experience. These technologies include cookies and similar tools, as well as analytical, advertising, and anti-fraud and anti-fraud technologies.
We and third parties use the technologies described below to collect information to help provide our Services.
A. Cookies and Similar Technologies
Cookies are small text files that are stored in your web browser. Cookies and similar technologies help us and our third party partners understand which web pages, sections or advertisements you are viewing and which games you are playing. This information helps us track your shopping cart in the online store, evaluate the effectiveness of our advertising, eliminate the recurrence of the same advertisements and improve the service provided to you in a different way. You can completely disable cookies, limit the number of their types, or configure your browser so that you receive a notification when cookies are sent. Please see the instructions in your web browser if you need help with your cookie settings. We also offer cookie consent tools in some regions to help you manage cookies.
We may use tracking pixels or blank GIFs to collect information about how you use our Services and respond to our marketing emails. We use internet log files (containing technical data such as your IP address) to monitor traffic on our Services, resolve technical issues, detect and prevent fraud, and enforce our User Agreement. We do not currently respond to DNT (Do Not Track) signals. You can opt out of certain types of online tracking, including certain analytics and personalized ads, by changing your browser cookie settings or using consent tools, if applicable.
We also use analytical and advertising technologies, technologies to protect against deception and fraud in our Services. These technologies may use the same cookies or similar mechanisms described below.
B. Analytical technology
We use internal and third-party analytics technologies to collect information about how you use our Services, what computer or device you have, and how efficient our Services are on your devices.
For example, the Company may collect and store data from your computer or device when you use our Services. This can be technical and other information about your computer, device and operating system (for example, IP address and device ID), information about your use of certain functions, gameplay and usage statistics, as well as information about interaction with the system and peripheral hardware. for the purposes specified in section 7 below. If you play the game offline without an Internet connection, this data will be stored on your device and transmitted to the Company after the device is connected to the Internet. If you use the Online Services, we may also collect, use, store, transfer and publish your personal and / or statistical data about your game (including points scored, ratings and success) or identify data that you have created and shared with other players.
C. Advertising technologies
These technologies collect and use information so that we can serve you relevant offers and advertisements, measure the effectiveness and distribution of such offers and advertisements, and understand how users interact with our Services. In addition to the identifiers and certain information listed in section 4 above, this information may include:
Third party advertising companies
Third-party advertising companies may combine information collected during the delivery of an offer to you through our Services with other information that they have independently collected on various websites. Many of these companies collect and use information in accordance with their own privacy policies.
To learn more about some of the advertising delivery methods and how to opt out of targeted third-party advertising, visit www.networkadvertising.org, www.aboutads.info/choices, youradchoices.ca, or www.youronlinechoices.eu. Please note that your opt-out does not mean that you will not see any ads. It is just that the ads you see may be less relevant to your interests.
E. Technologies to protect against deception and fraud
7. How we use your information
We use your information to operate our Services, improve your gaming experience, provide you with customer support, serve and measure advertising performance, and personalize our communications with you.
We retain the information we collect for as long as it is necessary to provide our Services, and we may retain such information even longer if required by legal, operational or other legitimate reasons.
We may also anonymize, anonymize or aggregate the collected information, or collect it in a way that does not directly identify you. We may use and share such information as necessary to conduct our business and as permitted by applicable law.
8. Information we provide to third parties
We do not disclose or provide your personal information to third parties, except as described in this section, for example, unless it is required to provide our Services and advertisements.
Service providers. We use third parties located in or outside of your country of residence, including outside the European Economic Area (EEA), to collect or process personal information for us for the purposes outlined in section 7. These purposes may include market research, providing IT and related services, assisting with credit card processing and online events, and sending emails or delivering and optimizing our Services. We require third parties to use the data only on our behalf and for purposes consistent with these guidelines.
Business partners. We may share personal information with business partners with whom we provide the Services. These partners include companies that provide the platform you play on or games.
Affiliates and Subsidiaries. We may share personal information with our companies in which we have a share of ownership as necessary for the purposes set out in this notice.
Advertising partners. Through our Services, we may allow third-party advertising partners to use technology and other tracking tools to collect information about your use of the Company's Services and your device (for example, information such as your IP address, mobile identifiers, pages viewed, location, browser data, Times of Day). We may also combine and share this and other information (such as anonymized information about your account, demographic information, equipment specifications, and purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) to serve you targeted advertisements when you visit third-party websites within their networks. This practice is commonly referred to as “personalized advertising” or “online behavioral advertising”. We may allow access to other data collected by the Services to provide information that may be useful, relevant, valuable, or otherwise interesting to you.
We may share information with other third parties with your explicit consent, unless otherwise described above. For example, you can give us consent to share your information with a particular company or organization in order to learn about its products, services or promotions, or if you tell us that you want to link your account with the services of another company. The use of the information you agree to provide is governed by the privacy notices of the respective third parties.
9. Where we store your information
We store and process your information in Singapore and other countries where we operate. In doing so, we use technical, physical and administrative safeguards to comply with data transfer requirements set by various privacy laws, such as the European General Data Protection Regulation.
The personal information we collect may be stored and processed for the purposes set out in this Privacy and User Identity Policy in Singapore and any other country where the company, its subsidiaries, partners or third-party agents operate. By allowing the transfer of personal data outside of your country of residence, you acknowledge that your personal data may be transferred to recipients in Singapore and other countries that may not provide the same level of privacy protection as required by the laws of your country of residence or citizenship.
The company's privacy practices comply with the APEC Cross Border Privacy Rules System (CBPRS). The APEC Cross-Border Confidentiality Rule System defines standards for organizations to protect personal information transferred between APEC countries. More information on the APEC Framework Programs is available on this page.
Whenever applicable, when transferring data outside the EEA, the United Kingdom and Switzerland, the Company will be governed by the EU's Standard Contractual Clauses and other safeguards. In accordance with the decision of the Court of Justice of the European Union of July 16, 2020 regarding the EU-US privacy program and the guidelines of the European Data Protection Council, the Company continues to monitor changes in the legal regime of the countries to which data is transferred and, as necessary, updates safeguards to ensure adequate level of protection. To find out more, visit this page.
10. How we protect your information
We use a number of security measures to keep your information safe and secure.
Protecting your information is our most important task, and we take a number of technical and organizational measures in this regard, including encrypting sensitive information. However, none of the security measures are perfect. Therefore, we cannot guarantee the continued security of your information. It is your responsibility to exercise due diligence in protecting your personal information.
11. Possibilities of choice and control
We give you the choice and control over our use of your information, including ensuring that you exercise your privacy rights.
We offer you a smart choice when it comes to our collection and use of your information.
Your Right to Erasure. You can deactivate your account or delete personal data associated with your account. In this case, you will lose access to the games or Services of the Company associated with this account. Please note that the company may retain information necessary to resolve disputes, comply with our user agreements and protect our legal rights, as well as to comply with technical and legal requirements and restrictions related to security, fair business conduct and operation of our Services. Otherwise, we will retain your personal information for as long as is reasonably necessary to provide you, create and improve our Services, and to comply with legal requirements. You can also close any account registered on the website by going into your account settings and selecting "Delete account" in the data management tab.
Your right to access. You can access your personal information that we hold. You can download a copy of your account data by logging into your account and clicking on the "Your data" tab or go to this page. To submit a request for access to additional data, please contact us on the website.
Your right to rectification. You can submit a request to correct your personal information if it is inaccurate or incomplete. In some cases, we provide self-management tools that will allow you to update some of your personal information.
Your right to refuse or object to certain processing methods. You can refuse to disclose, transfer or sell your personal information to third parties, if applicable, or object to any processing of your data if such requests are permitted by law.
You can also adjust your browser settings to block certain types of online tracking, such as cookies.
12. Third party services
Our websites and Services may contain advertisements or links to third party services and sites.
13. Changes to the Rules
These rules may be updated from time to time and you should check them on the website.
14. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
15. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
16. How to contact us
You can contact us if you have any questions about these Policy.
If you wish to contact us, please feel free to do so at the following email address [email protected] or at our mailing address: REDPAD GAMES PTE. LTD., 20 Cecil street, #10-03, Plus, Singapore (049705).