1DER ENTERTAINMENT - PRIVACY POLICY

Version 1.3, November 2023

updated on 15.11.23

We process your personal data when you engage with our games (like Tiny Archers), applications, websites, and software, or when we reach out to you, or in the case of a business relationship with you. In this privacy policy, we outline the circumstances under which we collect, use, process and secure your personal data.

Controller of your data

The controller of your personal data is 1DER Entertainment s.r.o., a company registered in the Slovak Republic, with an office in Budapest, Hungary.

General

As we reserve the right to modify provisions of this privacy policy and to update it periodically, we encourage you to review it regularly to stay informed about any alterations.

Personal Data Collection

There are several methods through which we may collect your personal data. In this section, we detail the types of personal data we might (but not necessarily do) gather from you. The processing of personal data is contingent upon your role and the specific processing purposes. The data retention period also varies depending on the processing objective.

Additionally, when feasible, we may anonymize your personal data for statistical and analytical purposes. Once personal data is anonymized, it ceases to be identifiable and is no longer considered personal data.

It is important to note that while our games may collect, use and process your data, we typically do not store this data ourselves. Storage and related retention periods are governed by the privacy policy of the third-party (platform holder, middleware provider, service partner).

a) If you are a player of our games

In order to deliver the game and the intended experience, we may (but not necessarily do) process the following personal data. Our legal basis for processing is the performance of a contract with you.

• Your in-game progression data (score, leaderboard position, etc.)
• Your in-game friends and relations
• Platform user-ID
• Your platform (Steam, Meta, etc.)

For the provision of matchmaking services, we may (but not necessarily do) process the following personal data:

• Username
• IP-address

To enhance our games, we may (but not necessarily do) process personal data. Our legal basis for this processing is our legitimate interest in improving our games:

• GPU and GPU driver
• The VR SDK in use
• The (VR) platform you utilize
• The VR headset, including its serial code
• Username (pseudonymized)
• IP-address
• Used peripherals
• Game version
• Game settings
• Owned DLC

Additionally, we may (but not necessarily do) process other analytical data, like:

• Platform user-ID
• Time, date, duration, and general location of game usage
• Time and date of connections with the matchmaking servers
• In-game statistics
• Device information

We may use the information you provided us, to contact you from time to time, to provide you with important information or required notices.

b) If you participate in our contests

This processing is based on your consent and is necessary to review your participation and ensure compliance with the contest conditions:

• Your general location (country level)
• Date of participation
• Date of birth
• Answers to the questions and/or actions taken for the contest

In the event that you emerge as a contest winner, we process the following personal data based on your consent to dispatch the prize:

• Name
• Address
• E-mail address

c) You are member of the media / press / influencer or business partner

Our legal basis for this processing is our legitimate interest in being able to respond to your requests:

• Name
• Company name
• E-mail address
• Telephone number
• Your work-related function
• Communication and content of e-mails
• Your general location (country level)

d) If you contact us as a player

If you contact us as a player, we process the following personal data:

• Name
• E-mail address
• Communication and content of e-mails

Data Transfer

Your data may be processed, outside of your country of residence and outside of the European Economic Area (EEA), such as in the United States. Privacy laws in this country may not provide the same level of protection as in your country or within the EEA. If this is the case, we provide an appropriate level of protection for your data and rely on legally recognised grounds for data sharing, such as EU standard contractual clauses.

Third parties that have access to data obtained by our games

We may (but not necessarily do) transmit data to external services:

Distributions platform: Our games may utilize the SDK provided by the platform/store from where you are buying the game (Meta, PlayStation Store, Steam, Viveport, etc.) mainly for the purpose of authorization and license validation. We might also utilize the distributor SDK for the purpose for providing player leaderboards or achievements.

Unity Analytics: We may also use Unity Analytics to help us improve our games. You can find Unity Privacy Policy under this URL: https://unity3d.com/legal/privacy-policy

Sharing Based on Legal Responsibility

We may share personal data with third parties when it is:

• Necessary to comply with our legal obligations,
• Necessary to fulfill legal requests from authorities,
• Required to respond to any legal claims,
• Necessary to protect the rights, property, or safety of us, our users, our employees, or the public,
• Required to protect ourselves or our users against fraudulent, abusive, inappropriate, or unlawful use of our services.

We will promptly notify you if possible, when a government agency makes a request related to your personal data, unless prohibited by law.

Merger or Sale (Part) of the Company

In certain instances, we may disclose, share, or transfer your personal data in the event of transferring part of our business. This could include (negotiations about) a merger, or sale of parts of the company. We will make every effort to minimize the impact on you by transferring personal data only when necessary and anonymizing where feasible.

Protection of Personal Data

The safeguarding of your personal data is of paramount importance to us. To ensure this, we have implemented appropriate technical and organizational security measures, including but not limited to physical and electronic measures to protect our databases, reducing the risk of unauthorized access, loss, or misuse of personal data, regular backups of personal data, and Timely addressing of vulnerabilities in the software to minimize risks.

It is important to note that while we take extensive measures to secure your personal data, we cannot guarantee absolute security during the transmission of personal data over the internet or during storage. We recommend considering this before sharing personal data.

Your Rights

Privacy legislation grants you specific rights regarding your personal data. These rights are not absolute, and we will assess whether we can reasonably fulfill your request. If we cannot do so or if it would compromise the privacy of others, we may refuse your request, and in such cases, we will communicate our reasons. You have the following rights:

Right of Access: You have the right to request information about the personal data we process concerning you. A copy of your processed personal data can be requested, with additional copies incurring a reasonable fee.

Right to Rectification: If your processed personal data is incorrect or incomplete, you can request adjustments or supplements.

Right to Erasure: You can request the deletion of certain (or all) personal data. Deletion depends on the purpose of processing. Data processed due to legal obligations or for agreement performance will only be deleted if no longer necessary for these purposes.

For data processed based on legitimate interest, deletion is considered if your privacy rights outweigh our rights or the rights of others. Data processed with consent is deleted upon withdrawal of consent or when required by law. Accidental processing, legal requirements, or the settlement of legal proceedings may also prompt data deletion.

Restriction of Processing: If you dispute the accuracy, believe unlawful processing has occurred, data is no longer needed, or you have objected to processing, you can request restriction.

Restriction may occur during dispute assessment, objection evaluation, or when no legal ground for further processing exists but you wish to retain the data. If processing is restricted at your request, the data may still be used for legal proceedings or dispute resolution.

Right to Data Portability: Upon request, we can transfer automatically processed data related to agreement execution or based on your consent to you or a designated party at reasonable intervals.

Exercising Your Rights

To exercise your rights, such as requesting access, correction, deletion, data transfer of your personal data, or withdrawing your consent or objecting to the processing of your personal data, please send your request to privacypolicy@1der-ent.com.

To prevent misuse, we request that you adequately identify yourself when submitting a written request for access, rectification, or erasure. You can achieve this by including a copy of a valid proof of identity, ensuring that your citizen service number and passport photo are screened off on the copy.

You can also remove the data stored in the single player leaderboards, cloud saves according to the current instruction provided by the Platform on which you are playing (Meta, Steam, etc.) If the game has integrated Unity Analytics, you can opt-out and delete all information collected directly from the game- on the Settings Window. If the game has Tournament functionality, we delete the leaderboard data from time to time. All data collected for the purpose of allowing for online gameplay (e.g., matchmaking, current game leaderboard) are deleted automatically after the room is closed.

Contact

If you have any questions, concerns, or comments regarding this privacy policy or our data processing, please reach out to us via email at privacypolicy@1der-ent.com (subject: Privacy Policy).

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