PRIVACY POLICY (For EU Residents)

GRAVITY INTERACTIVE, INC.

PRIVACY POLICY (For EU Residents)

(Effective Date: October 1st, 2019)

1. Introduction

We take privacy seriously, and we are committed to protecting personal data (the “Personal Data”) of our users (“you” or “User”) who reside in the territory of European Union and further including Iceland, Liechtenstein, and Norway who are under General Data Protection Regulation (the “GDPR”). This Privacy Policy (the "Policy"), which is based on the principles set forth the GDPR, describes the full scope of purposes and reasons for collecting and processing of Personal Data, determines and limits what Personal Data we collect and how we use it (several sections below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what rights and other control mechanisms are available to you as a User. This Policy applies where we are acting as a data controller concerning your data and is limited to data collected or received by us through your use of our Services (defined hereinafter). By using our Services, and agreeing to this Privacy Policy, you consent to our use of cookies under the terms of this Privacy Policy.

 

2. Who We Are

Gravity Interactive Inc. ("Controller"), jointly with Company’s affiliates and independent contractors (“Co-Providers”, collectively with Controller, "us," "our," or, "we"), provide mobile game named Ragnarok MMORPG (“Game”) and related services, including, without limitation, online communities for Game or social network services offered by us via warpportal.com or our branded websites (“Sites”) (collectively, our “Service(s)”). 

For clarity, Controller in the sense of the GDPR and other data protection or data privacy laws in the Member States of the European Union or the European Economic Area and other guidelines with a data protection nature regarding the Services is:

Company Name: Gravity Interactive, Inc.

Official Address: 7001 Village Drive Buena Park, CA 90621

Phone: 714-736-3415

Contact Email: warpportalmobile@warpportal.com

The Representative of Controller under Art. 27 can be contacted at warpportalmobile@warpportal.com.

Further, our data protection officer can be reached at:

Name : Chiwang, OK

Email : warpportalmobile@warpportal.com.

Address : 15F, Nuritkum Square R&D Tower (Sangam-Dong),

396 World Cup buk-ro, Mapo-Gu, Seoul, Korea

 

3. Purpose of Our Collecting Personal Data

We collect and process your Personal Data to perform the agreement concluded between you and us and according to Article 6(1) (b) of the GDPR. We process Personal Data for the following purposes:

• for the performance of our obligations under the contract you have entered into;

• for enhancing the security and safety of your Game accounts;

• to communicate with you about transactions made by you while using our Services or Game, as well as to send you notifications related to your account security such as notifications about password recovery requests, editing security settings, changing of e-mail or profile settings and similar;

• to send you information about updates in our Services or Game, about features on our Sites, about upcoming events (online and offline) and other information related to our Services or Game (in case you have not unsubscribed);

• to inform you about changes in our policies and legal documents;

• to communicate with you to resolve any problem you faced while using our Services or Game;

• to inform you about our activities (in case you have not unsubscribed); for developing new tools, products or services for you;

• to provide support, as well as technical support, including, but not limited to, Game and Services updates, product patches and fixes and other similar communications;

• for compliance with legal obligations that We are subject to (e.g., our obligations to keep certain information under tax laws);

• for the purposes of the legitimate and legal interests of us or a third party (e.g., the interests of other customers of ours), except where such interests are overridden by your prevailing legitimate interests and rights;

• to communicate with you when you take part in online or offline competitions, events or game tournaments organized or supported by us;

• to arrange your travel, receipt of gifts and awards, to which you may be entitled as a result of winning in online or offline competitions or events, etc.;

• to improve our Services and Game, as well as while requesting your feedback about our Services and Game.

The scope and purpose of the processing of your Personal Data, among other conditions for the processing, is specified in this Policy. We will notify you about any significant changes in our Policy and ensure your consent.

We do not collect sensitive data concerning Users’ racial and ethnical origin, biometric data, health data, their political, religious or philosophical beliefs, trade union membership, genetic, health or sex life among other Personal Data that is sensitive to fundamental rights and freedoms. You should be aware that if you at your own discretion post (publish) your Personal Data on forums, game chats or groups in social network related to our Services or the Game or use them as your login or as character’s names (disclose), your data become available and known to the public and you become solely responsible for the consequences of such disclosure.

 

4. Personal Data Processed For Our Performance of Services

We collect and process your Personal Data for the purposes related to providing to Users of our Services, namely: registration (creation) and operation of Game account, providing access to the Game account, formation and performance of the agreement with us on using the Services, providing the Game, the Services and Game access to Users, sending, processing of and responding to support tickets along with other communications with us, payment acceptance, improving Game and Services etc. For these purposes, we require and collect the following Personal Data (the “Compulsory Data”):

(1) Obligatory data, such as:

Compulsory Data is:

• e-mail

• User’s ID in the social network that is used for registration at Game (if applicable)

• place of User’s residence (location) and

Additional data (“Additional Data”) that may be additionally collected by us for the execution of the agreement made with Users related to the use of Services and the Game. Additional Data may be:

• cell phone number

• full name

• date of birth

• sex

• partial number of User’s ID

Compulsory Data is required for us to provide Services and the Game to Users and perform other obligations under the agreements concluded with Users. Request for erasing of such data may result in your inability of using our Services as set forth in below.

Compulsory Data may be collected through, namely:

• through registration with Services and/or with the Game;

• while contacting us via e-mail, fax, phone or mailing address of ours;

• while contacting our support team or otherwise;

• while using the forum, chats related to Services and/or the Game;

• while using Services and/or the Game otherwise (including information you provide to when participating in competitions, contests, and tournaments or responding to surveys, e.g. your contact details);

The Additional Data is not obligatory to provide by Users to us, is collected and saved for using the Game. We will inform you about it in the appropriate agreement regarding the Game.

Such Additional Data may also be collected to ensure security and confidentiality of your account, e.g. against unauthorized access and disclosure, including resulting from hacking and hacker attacks and/or or fraudulent access, to restore access to the User’s account, restore lost payment made by the User or for other purposes to provide Services and the Game to Users. We will inform you about it through Services, the Game, or other means of communication.

You may also freely provide Additional Data to us without its request upon your discretion and consent. Such data will be processed according to this Policy.

We may also collect non-personal information of Users and store it separately from the Personal Data as described below in the Policy. Such non-personal information can be connected to Personal Data in the case set forth in this Policy. We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Anonymous data, aggregated or not, may be shared with third parties.

Be also aware, that for the purpose of organization of game process, we collect information about your in-game activities, logs, and data on in-game transactions. Such data also used for Game violations detections (as well as Sites violations) to prevent or punish for cheating and unfair gaming behavior. This data is used for detection, investigation, prevention and, where applicable, and stored only for the minimum amount of time needed for this purpose. If the data indicates that a violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations. Also be aware that enjoying a certain User’s rights shall be in balance with rights and interests of other Users, as well as lead to balance and should not affect the rights and freedoms of other parties, including trade secrets or intellectual property.

We may request personal information from you in paper form or the support program. Providing this information by e-mail is not desirable because it cannot guarantee the security and confidentiality of the data. The decision on method of providing the data is left for your discretion.

The storage period of Compulsory Data, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, will be the validity period of relevant agreements with us, and no longer than 5 years after the termination of such agreements for accounting or tax records, unless there is a legitimate reason for a longer processing.

We keep records on correspondence with User, including support tickets along with other communications, for statistics purposes, to deliver, develop and improve our Service and the Game, to support Users in using the Services and the Game, to ensure security and confidentiality of the User’s account and data, to restore access to the User’s account, Services and/or to the Game, to restore lost payments made by the User etc.

Such information, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, is stored for the validity period of relevant agreements with us and 1 year after the termination of such agreements, including the Terms of Services unless there is a legitimate reason for a longer processing.

Anonymous data and non-personal information of Users are kept separately from Personal Data and stored for no longer than the validity period of relevant agreements with us.

(2) Payment Data

 When the User tops up his or her Game account or makes payments via application market such as Google Play or App Store (the “App Markets”), we and the App Markets that is chosen by the User to process the payment exchange with the following Payment Data:

• user ID from our billing system

• user ID in the payment system

• payment (transaction/order) ID

• date and time of payment (transaction/order)

• amount of payment (transaction/order)

• the currency of payment (transaction/order)

• signature of the authenticity of the request (payment) and

Additional Data in case credit cards are used for payment purposes may be:

• name of the cardholder;

• masked card number - 6 symbols and last 4 digits;

• country code (if applicable);

• address (if applicable).

Such Additional Data regarding credit card payment as mentioned is provided by the User directly to the payment systems under the terms of use of such system that the system may require Users to enter before processing the payment. We do not process such Additional Data.

The storage period of the Payment Data, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, is 5 years as required under applicable law.

(3) Process for promotional purpose

We may use your Personal Data, including e-mail and/or phone number, to send promotional or marketing information and news about the planned contests, promotions and similar events, news about our Services and the Game. If you do not wish to receive such information, you can unsubscribe from receipt of such information following the instructions as described in the corresponding messages or Game account interface.

(4) Process for Service notification purpose

We may use your e-mail and/or phone for sending notifications or other notifications, for example, in case of communication within the scope of response to your requests or other communications related to access to Our Services and/or the Game, password restoring or otherwise restoring access to the User’s account.

You can disable this feature at any time, though you will be unable to use such features, including being informed on login to your account.

(5) Process of Non-Personal Data for improvement and development

To provide quality Services and to justify your expectations of Our Services and/or Game, we collect anonymous data:

• name and version of the operating system,

• the size of RAM

• the size of available disk space

• parameters of the network channel and internet connection such as network bandwidth and delay from User’s computer to our servers, traceroute information between your PC and our servers, etc.

• other data that is mentioned in the Technical requirements to the Game

We collect information about your Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers, and crash data. We process and store such data also to evaluate development plans, provide updates to the Services and Game, bug-fixing.

Such information, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, is stored for the validity period of relevant agreements with us and 1 year after the termination of such agreements unless there is a legitimate reason for a longer processing.

(6) Process of IP (internet protocol) address for identifying you for the Service provision and the prevention of illegal use.

When you visit Sites, use our Services and/or the Game, we may gather and store the information about your IP address and other online identifiers of User’s devices and applications to determine your approximate geographic location. By using such identifiers, we provide you with information, Services, and the Game available at or intended for the territory where you are.

Also, information about the IP address and other online identifiers is used to prevent the illegal use of our Services and the Game if there is reason to believe that there is a risk to security of Our Servers (i.e. blocking of concurrent IP addresses).

We also collect a browser or device identifiers, browser type, operating system, crash data, Internet service provider, the date and time of your visit, information about your activities on the Services and other standard server log information.

The data on the IP address and other online identified, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, is stored no more than for 1 year from the moment of the agreement termination.

(7) Process of IP Cookies for analyzing your use of Services 

Cookies are small pieces of information stored by your internet browser on your computer’s hard drive. Like most website providers, we use cookies to make a link between you and the information you have provided to our Sites, Services and the Game and therefore provide you with personalized content so that we can give you a better experience when you return to the Sites, Services and the Game. To benefit from such features, you should accept and enable the use of cookies.

We would like to draw your attention that if you choose not to accept cookies, you will not be able to fully use all of the functions and benefits of our Services and the Game. By activating the cookies feature of your browser you agree and consent to the data collection and processing as explained herein.

We also use so-called authorization cookies, which are intended to store information and data submitted by the User on our website, to avoid you from multiple and/or repeated submission of such data in a single visit session or longer, if you wish, which increases the comfort of using website. Such data are stored for no longer than 15 days from the last visit of the User.

(8) Process of game data for the prevention of illegal user’s access

We collect data for the organization of the game process and collects information about your in-game character activities, logs, and data on in-game transactions. We also collect Game data and commands the so-called log files (information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal form), as well as the content of in-game chats (correspondence). We may use this data for decisions to ban a Game account or user’s character, according to the rules of the relevant Game.

Such data are not Personal Data and, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, stored for 1 year from the moment it is collected.

If the Game account or character was banned based on logs or chat correspondence, such data, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, is stored for 3 years after the violation unless there is legitimate ground for a longer processing.

In case of dispute with the User, log files and chats are stored during the period of the dispute.

In the event of litigation between the User and us or in case we receive a request from competent authority, such data can be combined with the personal information you provide and are stored during the period of resolution of the dispute.

(9) Security Measures

Our endeavors to implement technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure, or access. We, affiliates and third parties authorized to access the Personal Data, are required to give the undertaking to maintain such confidentiality and secrecy.

Among other measures, any information sent to us is encrypted (scrambled) using high qualified technology. This is industry-standard encryption technology that protects your data while being sent over the Internet from being intercepted and misused by third parties.

We have put in place, and regularly reviews and updates, appropriate physical, electronic, and managerial procedures to keep the data safe and help prevent unauthorized access, maintain data security and correctly use the information collected.

 

5. Sharing of User’s information

We do not transfer your data to anyone, except for those specified in this Policy or as provided by the GDPR, and this may be related to the provision of Our Services and performance of contracts you have concluded with us. If such transfer to third parties is related to any other purpose, we will ask for your explicit consent to such transfer.

We do not sell your personal information and does not receive benefits from any treatment of your data. We do not use your data for advertising or promotion of products and services of third parties, other than those listed here.

Chasing a goal of performing its obligations, we may share your data with the following categories of third parties.

(1) Regarding Payment systems, we may share your Personal Data such as:

Email address, IP address, information about in-game purchases, and other information you provide to us for the purpose of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User for payments and with which we may share your data are described at our Sites.

(2) With advertising partners, we may share your Personal Data such as:

Email address, nickname, IP address and other information for targeting, delivery, and measurement of online advertising, or otherwise facilitate transmittal of information that may be useful, relevant, or of interest to you.

(3) With data storage partners, we may share your Personal Data

Some of the information is stored using third-party data storage services, e.g. we store most of your responses to our in-game questionnaires using the services of data centers in London (DPO center in London). We provide personal information to our affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

(4) With Game developers and right holders, we may share such data as:

Non-personally identifiable information publicly and with our partners - like developers or rights holders. This information includes as a minimum your ownership of the game in question. It may also include your progress in the game, achievements you have completed, your multiplayer game matchmaking information, in-game items and other information needed to analyze, improve and fix game-related issues. We pseudonymize data to reach the only goal of upgrading the service level.

(5) For publicly available information

Our Sites may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum, or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one of our community forums and you want to remove such information, please inform us with request to its removal. If we may not be able to remove your personal information promptly, we will let you know about the reasons.

(6) With Anti-cheat and anti-fraud companies,

We may decide to share the information required for our detection, investigation, and prevention of cheating in the Game and violations of agreements related to the Game only for the purposes of detection, investigation, and prevention of cheating in the Game.

(7) With our subsidiaries and affiliates,

As a global company, we collect information that may be processed in our offices worldwide. Your information may also be processed outside of the European Economic Area, e.g., in the United States of America, or any other country in which we, our affiliates or subsidiaries maintain presence.

(8) When our control is changed

We may share your data as part of our company’s sale, merger or change in control, or preparation for any of these events. Any entity which buys us, or part of our business will have the right to continue using your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

When your Personal Data is shared with our affiliates and subsidiaries, we guarantee an adequate level of Personal Data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with our affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the standard data protection clauses upon your request.

(9) We also share anonymous data:

Such information which does not directly or indirectly disclose your identity, and aggregated information (meaning information about groups and categories of users, including game statistics and behavior, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Game and our Services, and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising on the Services and the websites of third parties so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.

6. Retaining and Deleting Personal Data

We retain your information only for the period of time as necessary to achieve the particular purpose for which the information was processed.  Typically, without your request to erase Personal Data and also without legitimate reason to keep it longer, we retain your information for 1 month after deregistration of your Game Account or for the duration described in the table below:

Information Retained

Retention Period

Records of an agreement or cancellation of subscription

Records of payment

Tax and accounting records

Records of electronic financial transaction

 

5 years

Records of a customer complaint or dispute resolution

Records that Game account or character was banned based on the violation.

 

3 years

Records of correspondence with User for statistics purposes; to deliver, develop and improve our Service and the Game; to support Users in using the Services and the Game; to ensure security and confidentiality of the User’s account and data; to restore access to the User’s account, Services and/or to the Game; to restore lost payments made by the User.

 

Record of User’s Game' preferences, progress in Game, playtime, as well as information about device settings, unique device identifiers and crash data.

 

1 year unless stipulated more specifically in other agreements

Record of IP address and other online identifiers

 

Record of in-game character activities, logs, and data on in-game transactions, log-files and in-game chats.

 

Records of misuse by users of Game or Services

 

1 year

Computer communication or internet log-in records of computer communication or facts about an internet user’s utilization of telecommunication service

 

3 months

Personal Data cannot be erased or anonymized when it is necessary to comply with the law. If you wish to change and/or erase your Personal Data, you can submit such request to our specialists at warpportalmobile@warpportal.com. Please be aware that if you have valid agreements on using our Services and/or the Game and submit the request on erasing and/or anonymization of your Personal Data, you may lose the ability to use our Services and the Game from the date when your request is completed.

When your data is incorrect or inaccurate, you must either amend it on your own or ask our specialists at warpportalmobile@warpportal.com.

If we find that you provided incorrect or inaccurate Personal Data, it may restrict (ban) your Game account until you amend it.

Payment data cannot be changed and/or erased at your request unless you provide us with the documented proof of the necessity to make such changes.

We do not erase the data if any violation or abuse has been occurred by Users or we have been summoned not to erase the data at competent authority’s request or court order. If a User requests the erase of the Personal Data, while a prior request (s) from that User is still being processed, such data can be erased only when the User has recalled/canceled all previous requests.

The data is stored separately. Your data may be combined with other data collected by us in exceptional cases, for example, in case of a violation by users of the agreement with us or the rules of the game, the availability of a dispute between us and the User, conduct of financial control and accounting, etc. As for the detecting violations, be aware that we use anti-cheating tools that collect information about the processes in use while you are accessing Game.

The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable. The user may edit his personal information having access to his private account. All changes are logged.

For the clarity, we may retain your information insofar as such information will be processed solely for archiving purpose in the compliance with our legal obligation, public interest, scientific or historical research purposes or statistical purposes, subject to appropriate safeguards, in accordance with the data protection laws, for your rights and freedoms.  Note that in some circumstances, you have the right to request us to delete the information.  The appropriate safeguards shall ensure that technical and organizational measures are in place to ensure respect for the principle of data minimization.

 

7. Transfer of Personal Data to Third Country

Your Personal Data may be transferred globally, either within or outside the European Economic Area (“EEA”), including to a country or territory that may not have equivalent data protection standards.  In all cases, appropriate security measures for the protection of Personal Data will be applied in those countries or territories, under applicable data protection laws.  

 

8. Security of Your Information

We take appropriate technical and organizational measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, sensitive data that you share and we collect and store.  Despite our efforts to enhance the security level of the Service, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.  We strongly encourage you not to share your account password with any third parties for any reasons.  Also please note that email and messaging systems are not considered secure, so we discourage you from sending us Personal Data through these mediums.  If you have questions regarding the security measures of the Service, please contact our specialists at warpportalmobile@warpportal.com.

 

9. Our Policy Concerning Children

Children under the age of 16 can only use our Game or our Services with valid consent from their legal representative (e.g. parents).  We make reasonable efforts to verify if consent from or any contract concluded with such children is valid by offering users age verification methods and by obtaining clear consent from children’s legal representatives. If we learn that we have inadvertently gathered Personal Data from such children, we will take reasonable measures to promptly erase such information from our records. If children under 16 or their legal representative ask us to cease processing or profiling of the child’s Personal Data for the purposes of direct marketing, we will immediately do so.

 

10. Your Privacy Rights

 

(1) Right to Access

You are entitled to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information.  That additional information includes details of the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data.  Provided, the rights and freedoms of others are not affected, we will supply you a copy of your Personal Data. You can access your Personal Data by logging into your Game account or contacting us at warpportalmobile@warpportal.com.

To manage the information we receive about you from an SNS, you should change your privacy settings on the SNS under any applicable policy of the SNS. 

 

(2) Right to Rectification

You are entitled to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed. You may change or update the profile information by logging into your Game account or by contacting us at warpportalmobile@warpportal.com.

(3) Right to Erasure

In some circumstances, you are entitled to the erasure of your Personal Data without undue delay.  Those circumstances include: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and (iv) the Personal Data have been unlawfully processed.  However, there are exclusions of the right to erasure.  The general exclusions include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation; or (c) for the establishment, exercise or defense of legal claims.

If you choose to terminate or delete your Game account, we will immediately delete your Game account information.  Even after your account is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been incorporated into any User contents or copied, stored or disseminated by you or other users.

You may request the erasure of your information by visiting the Sites or by contacting us at warpportalmobile@warpportal.com.

 

(4) Right to Restrict Processing

In some circumstances, you are entitled to restrict the processing of your Personal Data.  Those circumstances are: (i) you contest the accuracy of the Personal Data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection.  Where processing has been restricted on this basis, we may continue to store your Personal Data.  However, we will only otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the protection of the rights of another natural or legal person; or (d) for reasons of important public interest.

You may request the restriction of the processing of your information by visiting the Sites or by contacting us at warpportalmobile@warpportal.com.

 

(5) Right to Object to Processing

You have the right to object to our processing of your Personal Data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You may object to the processing of your information by visiting the Sites or by contacting us at warpportalmobile@warpportal.com.

 

(6) Right to Object to Processing for Direct Marketing Purposes

You are entitled to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose. 

You may object to the processing of your information for direct marketing purposes by visiting the Sites or by contacting us at warpportalmobile@warpportal.com.

 

(7) Right to Object to Processing for Scientific, Historical, or Statistical Purposes

You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. 

You may object to the processing of your information for scientific, historical or statistical purposes by visiting the Sites or by contacting us at warpportalmobile@warpportal.com.

 

(8) Right to Data Portability

To the extent that the legal basis for our processing of your Personal Data is: 

  • - consent; or
  • - that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract,

and such processing is carried out by automated means, and you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another controller.  However, this right does not apply where it would adversely affect the rights and freedoms of others.

You may request to receive your information by visiting the Sites or by contacting us at warpportalmobile@warpportal.com.

 

(9) Right to Complain to a Supervisory Authority

If you consider that our processing of your Personal Data infringes data protection laws, you are entitled to file a complaint with a supervisory authority responsible for data protection.

You can find more details of the supervisory authority in your country by visiting

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

 

(10) Right to Withdraw Consent

To the extent that the lawful basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time.  Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may withdraw your consent at any time in the Game setting or contacting us at warpportalmobile@warpportal.com.

You may also exercise any of your rights concerning your personal data by written notice to us at warpportalmobile@warpportal.com. 

  

11. Change/Update to Privacy Policy

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy within and/or on the Sites.  You will be deemed to have accepted such amendments by continuing to use the Service.  Except as otherwise stated, any such amendments will be automatically effective after they are initially posted.  Our policy will be regularly updated.  We will notify you of the changes where required by law to do so.  This policy was last updated on September 23rd, 2019.

 

12. Links

The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party. We are in no way responsible for the privacy policies of these other websites to which you choose to access from the Services. It is your responsibility to read the privacy policies of these other websites when exiting the Services.

 

 13. Questions

If you have any questions regarding our Privacy Policy and/or practices, please email us at warpportalmobile@warpportal.com.