Privacy notice for players of Carrumble on data processing

PURSUANT TO ART. 13 AND 14 OF EU REGULATION 2016/679 (GDPR)


SUMMARY

The GDPR recognise as a fundamental right the protection of natural persons in relation to the processing of their personal data. 3DClouds S.r.l. values the trust you place in us and takes your privacy very seriously. 3DClouds S.r.l. collects data when you use CARRUMBLE and this privacy notice explains how we collect, use, share and protect your data, as well as your rights.
  1. Data Controller

    Controller is the company 3DClouds S.r.l., Via Privata Tarvisio, 32, 20125 Milano, VAT 05433260964, REA MI-18212182019, contact e-mail: privacy@3dclouds.it

  2. Categories of data

    The data categories processed by Controller concern data related to the Player (such as Steam ID of the Player and nationality of the IP, etc.) and data generated while gaming (Player level, daily quests completed, time spent in the virtual shop, etc.).
    Full list of data categories processed.
    Data are usually collected directly from the Player when gaming or by the platform STEAM according to its privacy policy. Aggregated data and statistics are elaborated by Game Analytics.

  3. Purposes of processing

    1. Data collected from the Player while using CARRUMBLE and data communicated by STEAM are processed by the Controller for the following purposes:
      1. Allowing the Controller to provide its Service to the Player (CARRUMBLE Game)
      2. Statistics to generate the aggregated data

    2. Aggregated Data and statistics concerning collectively the Players are elaborated by Game Analytics and are processed for the following purposes:
      1. Game tuning and providing Players a better experience
      2. Understanding the Target of Players and Preferred Choices when playing.
      3. Understanding the preferred items purchased by Players also for marketing purposes.
  4. Legal basis for processing

    The legal basis for processing personal data consists of:

    • performance of the contractual obligations between the Controller and the Player;
    • legitimate interests of the Controller, such as improvement of service quality, providing offers and discount on the items, provided that the interests and rights of the interested party do not prevail according to a balancing assessment performed before each processing and without prejudice to the right of opposition of the data subject for certain processing based on the legitimate interest of the Controller.

  5. Communication of personal data to third parties

    The data processing is carried out by the Controller also through data processors and / or external data processors and their representatives, in compliance with current legislation. The above described personal data shall be shared by the Controller with Game Analytics and Prex S.r.l. that takes care of the IT infrastructure maintenance.
    The Controller has taken the necessary technical and organizational data protection measures to guarantee the confidentiality, integrity and availability of personal data and in particular to prevent unauthorized access, alteration, diffusion, loss or destruction.

  6. Duration of processing

    Personal data are processed for all the duration of the contractual relationship and for two years after its termination or even for a longer period, if this is required by the circumstances (e.g. in the event of a dispute).

  7. Data subject’s rights

    Data subject has the right to obtain free information on processing of its personal data, including the origin of personal data, the purposes and methods of processing, the logic applied in case of processing carried out with the aid of electronic tools, the subjects or categories of subjects to whom the personal data has been communicated.
    The data subject also has the right to obtain:

    1. updating, rectification or, when interested, integration of data;
    2. cancellation of data;
    3. blocking of data processed in violation of the law and those that do not need to be kept for the purposes for which the data were collected and subsequently processed; The data subject has the right to object, in whole or in part, on processing based on legitimate interest to the processing of personal data.

    At the request of the data subject, the Controller will limit the processing of personal data provided by the data subject.
    Requests for deletion of data will be considered within the limits of the permitted, taking into account the legal and contractual obligations related to data retention. Data subjects will be considered identified for the purposes of data deletion if they provide the following data: their device ID (IDFA or GAID) as well as the specific platform - i.e. Paper.io iOS, and the last date on which they played.
    The subject may at any time exercise their rights by sending an email to privacy@3dclouds.it In any case, any request received by the Controller will be taken into consideration upon verification of the identity of the entitled person.

  8. Complaints

    For any complaints, the interested party may write to the Controller by direct addressing the request by mail to privacy@3dclouds.it without prejudice to their right to contact the Authority responsible for the protection of personal data www.garanteprivacy.it or the authority of the different European country in which they live or work.

  9. Other information

    This privacy notice may undergo changes in the future. The new editions of the information will show the date of their dissemination or publication.


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Full list of data categories processed:

  • User IP
  • IP nationality
  • Device used
  • OS system
  • OS system version
  • Steam ID
  • Most used vehicle and victory percentage using it
  • Most used moves and most effective ones
  • Damages dealt and taken
  • Arenas played
  • Players performances in-game involving vehicles destructions made and suffered
  • Time spent in several places of the game like effective gameplay and shop
  • Player’s nationality
  • Player’s time slot used in order to play the game
  • Virtual currency wallet management
  • Player and vehicles ranks
  • Time spent to unlock achievements
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For any further information and clarification, the business partner can send an e-mail to: privacy@3dclouds.it

Milan, September 17th 2019

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