PRIVACY AND DATA POLICY
ISSUED BY MODERN WOLF Limited
Last updated: January 2020
1. GENERAL STUFF
This policy (the “Privacy Policy”) applies to the use of MODERN WOLF LIMITED’s (“Modern Wolf” / “we” / “us” / “our”) website (available at https://modernwolf.net/), videogames (including ““NECRONATOR: DEAD WRONG” ”) (the “Game(s)”), and the use of other online services relating to the Games for which this Privacy Policy is made available (together, “Service”). Our registered office is at One London Square, Third Floor, Cross Lanes, Guildford, Surrey GU1 1UN, United Kingdom.
We are a company registered in England and Wales, with company number 11956982.
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If you have any questions or comments about this Privacy Policy, or if you want to exercise your rights, you can contact us at Hello@modernwolf.net. |
We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose and means for which personal data you supply through this Service is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (GDPR) and the UK Data Protection Act 2018.
Please read this Privacy Policy carefully as it contains important information about the following:
- What information we may collect about you;
- How we will use information we collect about you;
- Whether we will disclose your details to anyone else; and
- Your choices and rights regarding the personal data we hold about you.
This Privacy Policy should
be read in conjunction with our EULA, available here.
The Service may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
We may make changes to this Privacy Policy in the future, which will be made available here. You should check here from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes by email or through the Service.
2. PERSONAL DATA WE MAY COLLECT ABOUT YOU
We may collect and process the following personal data from you when you use our Service:
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Information provided by you when registering for, or otherwise submitted during use of, the Services (“Submitted Information”) o Your email address; o Your first name; o Your account password for the Service. |
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Information that may be provided by you when you contact us for support (“Contact Information”) o Your full name; o Your address (if you choose to provide this); o Your email address; o Your telephone number (if you choose to provide this). |
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Information about your in-Game activities (“Game Analytics”) We may collect technical information about use of our Service through the use of tracking technologies and analytics. Personal data we may collect in this way includes the following: o Unique Player ID (e.g. Steam ID); o IP address; o Device information (e.g. device ID and browser type); o Language, Country, Timezone; o Error Logs; and o ‘Events’ related to your Game and Service usage, such as achievement of a milestone and the occurrence of other particular events during your usage (such as session durations, progress, page and menu usage, buttons clicked and screens viewed, timings and choices for different parts of the Service). |
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Information collected by Cookies and similar Technologies (“Website Analytics”) Our website uses cookies, and other mechanisms to collect log and analytical information, to help analyse how visitors use the site, to compile statistical reports on website activity and to improve our marketing function. To find out more about the use of cookies, please visit http://www.allaboutcookies.org/. Our website uses Google Analytics to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. When you visit our website, our analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us: o number of visitors to our website; o pages visited while at the website and time spent per page; o page interaction information, such as scrolling, clicks and browsing methods; o websites where visitors have come from and where they go afterwards; o page response times and any download errors; and o other technical information relating to end user device, such as IP address or browser plugin Most web browsers allow some control of most cookies through the browser settings. |
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Information collected via our Social Media channels (“Social Media Information”) The website contains links to our channels on Facebook, YouTube and Twitter. These third party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible. Should you visit our social media pages and choose to follow or connect with us on social media, we may receive personal information from the social media providers (depending on your social media privacy settings), including: o your name (and/or your social media unique user name); o your email and/or postal address; o your telephone number(s); o IP or MAC address; o your gender and/or age; and o your general interests and preferences (e.g. Likes, Shares, Posts) |
3. WHAT WE DO WITH YOUR PESONAL DATA AND WHY WE DO IT
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To provide the Service to you We will process data about you (including the Submitted Information) to process your account registrations and to deliver our Service to you under the terms of use agreed between us (such as our EULA). The processing of information in this way is necessary, for us to record your progress and current status within a part of the Service (such as the Game), in order to provide you with updated parts of the Service (such as for security patches or content updates) and to ensure the Service delivers the features promised and functions properly. For these purposes, we rely upon the legal basis of performance of a contract (being performance of the terms of use agreed between us) and our legitimate interests (being our commercial interests in providing enhanced services and functionality to you). |
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To respond to your enquiries and requests for support We will process personal data about you (including your Contact Information) so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us. For the above purposes, we rely upon the legal basis of performance of a contract (being our terms of use with you for the Service) and our legitimate interests, being our commercial interests to respond to your queries and requests for support. |
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To keep you up to date about our services and products Where you have consented, or where it is otherwise lawful for us to do so, we may use your personal data to send you emails in order to keep you informed about our Modern Wolf-related news, services and products or in connection with the Game. In line with the legitimate interest we have in promoting our business, we will use the email address you gave us via the Service to provide you with this information. There may also be circumstances where we will ask you for your prior consent in respect of our use of your personal data for direct marketing. Where we rely upon your consent to do this activity, you can withdraw your consent at any time upon email to Hello@modernwolf.net We hope that you would like to receive our updates, but we do not want to send you emails that are not of interest for you. If you would like to be removed from our mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us. |
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Operating our Social Media Channels We may process personal data, including the Social Media Information, to engage with users on our social media channels and to find out how users interact with our social media channels. We process this personal data on the basis of our legitimate interests, being our interests in engaging with our users and promoting the commercial success of our Game (including by improving our advertising and marketing). |
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Website Analytics We may process personal data, including the Website Analytics, to find out how users visit and interact with our website and use our Service. We process this personal data on the basis of your consent (where applicable) or our legitimate interests, being our interests in promoting and improving our Games and their commercial success (including by improving our advertising and marketing). |
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To prevent fraudulent or illegal activity We will process personal data about you for our legitimate interests of ensuring that your use of our Service is lawful and in compliance with our agreement (being the terms of use agreed between us), to prevent disruption to our Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations. |
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To help us to understand usage of the Service, improve the Service and to help us to fix any problems We may process personal data about you, including the in-Game Analytics Information, so that we can understand usage of our Service, analyse and improve our Service and develop new services or new parts thereof. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in: (i) ensuring that our Service functions properly so that you and other users have the best experience; (ii) improving the quality of our Service; (iii) identifying and correcting any bugs or problems with the Service or any part thereof; and (iv) developing and creating new services in the future. Where our processing activity relates to detecting and fixing problems with the Service, we also rely upon the legal basis of performance of a contract (being our terms of use with you for providing the Service). |
4. DATA SHARING
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We will share your information with third parties only in the ways that are described in this Privacy Policy Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it. Merger or acquisition: If we are involved in a merger, acquisition, transfer or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information. Required by law: We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention). Enforcement: We may also disclose your personal data to third parties (e.g. our licensors, app operators, stores or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Modern Wolf, our customers or others. Steam: We offer the Game through the Steam platform (“Steam”), which is hosted by Valve S.A.R.L. (in the EU) and Valve Corporation (in the US). That means you need a Steam account to play the Game via Steam, and your use of Steam is subject to the Steam Subscriber Agreement, which you can find online here. We may disclose your personal data to Steam for the purposes of facilitating your download and any payments made through Steam. Steam has its own privacy policy here, which we would advise you to read), for which those Steam is solely responsible. |
6. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply with requests without undue delay and within one month at the latest.
To make a request, please let us know via Hello@modernwolf.net.
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Ask for a copy of personal data we are processing about you and have inaccuracies corrected or request erasure You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected. You can request a copy by emailing Hello@modernwolf.net. We will use reasonable efforts, to the extent required by law, to comply with requests to supply, correct or delete personal data held about you on our files (and request that any third parties to whom it has been disclosed to do the same). |
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Object to us processing personal data about you You can ask us to restrict, stop processing or delete your personal data if:
You can request account deletion by sending an email to Hello@modernwolf.net. |
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Obtain a machine-readable copy of your personal data, which you can use with another service provider
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Make a complaint to a Supervisory Authority
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7. DATA RETENTION
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. CHILDREN
We do not use our Service to knowingly solicit information from, or market to, children under the age of 13.
As further set out in our EULA, you’re only allowed to use the Game and send personal information to us if you are either 18 years or older, or you are 13 years or older and your parent or legal guardian has read our EULA and explained it to you, and provided us with their consent to your use of the Game.
In the event that we learn that we have collected personal data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at Hello@modernwolf.net.
9. SECURITY
We will take reasonable and appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Service, taking into account the likelihood and severity those risks might pose to your rights and freedoms.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Service and your personal data a high priority, no security system can prevent all security breaches.
Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot always guarantee the complete security of your data transmitted through our Service. Subject to applicable law, the sharing of your personal data with us and any transmission of the data is at your own risk.
11. INTERNATIONAL DATA TRANSFERS
The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and work for us or our suppliers. These staff may be engaged in the maintenance of the Service, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Where your personal data is transferred outside of the EEA to a territory not subject to an adequacy decision by the European Commission, we have agreements in place with the relevant parties which include either (i) standard data protection clauses adopted by the relevant data protection regulator and approved by the European Commission or (ii) standard data protection clauses adopted by the European Commission, to ensure that appropriate safeguards are used to protect your personal data. Alternatively, we may put in place other appropriate safeguards. If you require more information about these safeguards, you can contact us at Hello@modernwolf.net.
12. CONTACT INFORMATION
All questions, comments or enquiries should be directed to Modern Wolf at Hello@modernwolf.net. We will endeavor to respond to any query or questions within a reasonable amount of time.
© 2020 MODERN WOLF LIMITED. All Rights Reserved.