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Home / Privacy Policy
Effective Date: July 21, 2024
We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Default Company OÜ. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the username or e-mail address of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Default Company OÜ. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, the Default Company OÜ has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website and game. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
The data protection declaration of the Default Company OÜ is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). 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, organisation, 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 analyse 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
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 authorised 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.
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Default Company OÜ Magdaleena tn 15 11312 Tallinn Estonia Email: [email protected] Website: www.default-company.com
The game of the Default Company OÜ collects a series of general data and information. The Personal Information we may collect is listed below.
| Personal Information | Purposes |
|---|---|
| Username | To create an account for our game
To play our game To monitor and respond to inappropriate or reported conduct in-game To send invites to your friends to play our game |
| Device IDs and device information | To provide an account for our game
To provide authentication To display active game sessions to you |
| Unique or provider ID (such as an account ID) | To create an account for our game
To play our game To monitor and respond to inappropriate or reported conduct in-game To send invites to your friends to play our game To link your game account to your other IDs |
| Language preference | To provide a localized experience in our game |
| DLC Purchase History | To fulfill in-game purchases across game platforms |
| Internet Protocol address | To monitor and respond to inappropriate or reported conduct in-game
To improve our game To play our game |
| gameplay Information | To play our game
To monitor and respond to inappropriate or reported conduct in-game |
| Diagnostics Information (Optional) | To improve our game |
We do not knowingly or intentionally process any sensitive Personal Information.
When using these general data and information, the Default Company OÜ does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our game correctly, (2) optimize the content of our game as well as its advertisement, (3) ensure the long-term viability of our information technology systems and game technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Default Company OÜ 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.
We may collect your Personal Information when you provide it to us directly, including the examples below.
We may collect your Personal Information automatically as you use our Services. For example, we may collect your Personal Information as you interact with our website or as you play our game.
We may get your Personal Information from third parties that help us provide or facilitate access to our Services, including:
We follow this Policy when using Personal Information provided by third parties. However, we do not control how these third parties collect or use your Personal Information. You should review their privacy policies to understand how they collect, use, and share the Personal Information they obtain and use.
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Default Company OÜ, he or she may, at any time, contact any employee of the controller. An employee of Default Company OÜ shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Default Company OÜ will arrange the necessary measures in individual cases.
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Default Company OÜ, he or she may at any time contact any employee of the controller. The employee of the Default Company OÜ will arrange the restriction of the processing.
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of the Default Company OÜ.
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The Default Company OÜ shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the Default Company OÜ processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Default Company OÜ to the processing for direct marketing purposes, the Default Company OÜ will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Default Company OÜ for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the Default Company OÜ. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Default Company OÜ shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Default Company OÜ.
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Default Company OÜ.
The Default Company OÜ may use third-party services to provide the services of our game. The Default Company OÜ has implemented the necessary technical and organizational measures to ensure the most complete protection of personal data processed through these third-party services.
Unity Technologies: We use Unity Authentication, an authentication service offered by Unity Technologies SF, 30 3rd Street, San Francisco, CA 94103, and Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland. Unity may use automatic data collection technologies to collect Personal Information directly from your device and use this Personal Information to help us securely authenticate your account while playing our game. You should review Unity’s Privacy Policy.
Functional Software, Inc. d/b/a Sentry: After opt-in, we may use Sentry, a diagnostics service offered by Functional Software, Inc. d/b/a Sentry. Sentry may use automatic data collection technologies to collect your Personal Information on our behalf to help us improve our game (such as your Internet Protocol address, device information, purchase history, and game play information). For more information about Sentry’s privacy practices, you can review its Privacy Policy.
Google LLC: We use Google Play Games Services, an authentication service offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google may use automatic data collection technologies to collect Personal Information directly from your device and use this Personal Information to help us securely authenticate your account while playing our game. You should review Google’s Privacy Policy.
Apple Inc.: We use Apple Game Center, an authentication service offered by Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA. Apple may use automatic data collection technologies to collect Personal Information directly from your device and use this Personal Information to help us securely authenticate your account while playing our game. You should review Apple’s Privacy Policy.
Valve Corp.: We use Steamworks, an authentication service offered by Valve Corp., 10400 NE 4th Street, Bellevue, WA 98004, USA. Valve may use automatic data collection technologies to collect Personal Information directly from your device and use this Personal Information to help us securely authenticate your account while playing our game. You should review Valve’s Privacy Policy.
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
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.
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.
As a responsible company, we do not use automatic decision-making or profiling.
Parts of this privacy policy have been developed by the specialists for LegalTech at Willing & Able that also developed the system for esign agreement. The legal texts contained in the privacy policy generator have been provided and published by Prof. Dr. h.c. Heiko Jonny Maniero from the German Association for Data Protection and Christian Solmecke from WBS law.
