Privacy and cookies policy
Information we collect
- Purposes and legal bases for processing
- Direct Marketing
- Recipients of the personal data
- Retention of data
- Access and Correction of Personal Data
- Your rights under the GDPR
- Information we collect
- How we collect information from You
- Why do we use your data? (LEGAL GROUNDS FOR DATA PROCESSING)
- How we hadle your information
- How do we use Your information
- Other stuff
- User agreement
1.3. A4G will take all practicable steps to ensure the security of your personal data and to avoid unauthorised or accidental access, erasure or other use of your personal data. This includes physical, technical and procedural security methods, where appropriate, to ensure that your personal data may only be accessed by authorised personnel.
1.4. Please note that if you do not provide us with your personal data (or relevant personal data relating to persons appointed by you to act on your behalf) we may not be able to provide the information, products or services you have asked for or be able to process your requests. Where we need your personal data to enter into or perform a contract, we will mark the required information with an asterisk. In some cases you may be legally obliged to provide your personal data – we will indicate this when collecting the data.
2. Purposes and legal bases for processing
2.1. From time to time we may collect your personal data including but not limited to your name, mailing address, telephone number, email address, date of birth, login name, payment instrument and transaction details and unique identifiers assigned to you for the following purposes:
2.2. From time to time we may also collect personal data from other sources that the data subject – for example when we identify beneficial owners within AML process or if you provide us personal data of other persons. In many cases providing information included in this policy to such persons proves impossible or would involve a disproportionate effort. We appreciate if you may help us to be transparent to such persons on processing of their data. Such data are not used for marketing purposes.
3. Direct Marketing
3.1. Where you have given your consent and have not subsequently opted out, we may also use your name, mailing address, telephone number and email address to send promotional materials to you and conduct direct marketing activities in relation to A4G products and services, and products services offered by other members of A4G, or products and services offered by relevant third-parties.
3.2. If you do not wish to receive any promotional and direct marketing materials or do not wish to receive specific types of promotional and direct marketing materials or do not wish to receive such materials through a specific means of communication, you can unsubscribe or change your settings by clicking the link provided in the marketing materials you receive. You can also unsubscribe here or contact us through one of the communication channels set out in the “Contact Us” section below.
3.3. Where you have given your consent and have not subsequently opted out, we may also collect information about what is watched and bought by you, at what price, in what amount or whether did you add specific products to the cart but did not buy them and use it to create a profile of your interests on the basis of content that we think was interesting for you (for example because you added it to the cart) as well as content that other users similar to you have found engaging. By using this profile of your interests we can adapt our marketing materials by replacing the default content with content more relevant to your interests (for example we can show you games or other products that we think you might like instead of the default offers).
4. Recipients of the personal data
4.1. We may transfer your personal data to the following categories of recipients:
- other users of our products and services where this is necessary to perform our agreements with you, for example when you purchase a game from us
- other members of the A4G as our partner
- agents, contractors, advisors or third parties who provide administrative, telecommunications, computer, payment, debt collection, data processing, legal or other services to A4G
- financial institutions, payment service providers (such as banks, payment institutions or electronic money institutions) as well as card organizations (such as VISA or MasterCard) – in connection with our payment services
- persons and institutions that are allowed to request your personal data under applicable laws and regulations through a court order, subpoena or other legal process, such as supervisory bodies, regulators or law enforcement bodies;
- other parties as notified to you at the time of collection.
4.2. A4G operates internationally. If personal data is transferred from European Union outside European Economic Area, we make sure that adequate level of personal data protection is assured, for example by signing standard contractual clauses for transfer of data.
5.2.Cookies are used for the following purposes:
- For statistical purposes through (analysis of aggregate data on traffic and manner of use of our websites)
We create statistics that help us understand how you access A4G, which allows us to improve the structure of A4G and its content and thus improve your experience;
- Creating a profile for you in order to display matching materials in regard to advertising networks, such as the Google Display Network.
- To run statistics on traffic to reliably conduct settlements with advertising partners.
- To remember your settings between browsing sessions and customize the Site to better suit your needs and preferences, such as selecting the display language or currency.
- For marketing purposes, also on the basis of automated processing containing profiling elements, in particular, for adaptation of our websites, offers and advertising to your interests.
5.4. To achieve the above goals, the Site uses two basic types of cookies, session cookies and persistent cookies. Session cookies are temporary files that are stored in your browser until you logout, leave the website or close the browser. Persistent cookies are stored in your browser for a longer period of time, as specified in the parameters of the cookie or until you remove the cookie.
5.5. Cookies may be used by partners and advertising networks, such as the Google Display Network to display ads specific to you and in accordance your preferences while using A4G. To achieve this goal cookies may store information about your navigation path or the time you spent on A4G. To see what information was collected about you by the Google Display Network, you can view and edit the information derived from cookies with the following tool provided by Google.
5.6. Your browser’s default setting is likely set to allow for the storage of cookies. You can change your browser’s settings and delete or prevent cookies. For details, consult your browser’s documentation. Please note that if you do so you may not be able to utilise or activate certain functions available on A4G.
The list of specific cookies (and similar features) that we use, their purposes, typical parameters and storage period is available below:
6. Retention of data
6.1. We will retain your personal data for as long as we have lawful grounds to do so. Specific retention periods depend on the purpose and legal base of processing, for example:
- personal data required to provide services, for the time of providing such services and after that, for the time required by legal provisions (e.g. on accountancy) or to handle possible claims
- personal data that must have been collected for anti-money laundering legislation requirements, including for identification, screening and reporting, as a rule for 5 years after the termination of our relationship, unless we are required to retain this information for the purposes of court or administrative proceedings, or 8 years to handle possible claims
- personal data processed on the basis of your consent, as a rule until such consent is withdrawn
- personal data processed on the basis of a legitimate interest, as a rule until you file an effective objection.
7. Access and Correction of Personal Data
7.1. Under the PDPO, you have the right to verify whether we hold your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request us to inform you of the type of personal data held by us. All data access requests shall be made using the form prescribed by the Privacy Commissioner for Personal Data (“Privacy Commissioner”) which may be found on the official website of the Office of the Privacy Commissioner or via this link.
Requests for access and correction of personal data or for information regarding policies and practices and the kinds of data held by us should be addressed in writing and sent by post to us (see the “Contact Us” section below).
A reasonable fee may be charged to offset our administrative and actual costs incurred in complying with your data access requests.
8. Your rights under the GDPR
8.1. Pursuant to the GDPR you also have the following rights:
- Right to be informed, which is satisfied through this notice.
- Right to erasure. You have the right to have your data erased and no longer processed if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, if consent was withdrawn or objection was filed and there are no other legal basis for processing. If we have disclosed the personal data in question to third parties, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.
- Right to restriction on processing. If there are grounds for restriction on processing, for example if you contest the accuracy of your personal data, it will be stored and processed otherwise only if you consent or to exercise legal claims, or for the protection of rights of another natural or legal person. If we have disclosed the personal data in question to third parties, we will inform them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so. We will inform you before the restriction is lifted.
- Right to objection to processing. You have the right to object to processing based on legitimate interests (including profiling) and direct marketing (including profiling). We will no longer process you data, unless we have compelling legitimate grounds for processing or we need to process the data for the establishment, exercise or defense of legal claims.
- Right to portability. You have the right to receive personal data that you provided to us in a structured, commonly used and machine-readable format and to transmit those data to another data controller.
You may contact us to exercise your rights through “Contact us” section below.
- Right to lodge a complaint with a supervisory authority. If you are unhappy about the way we process personal data you may contact us and, if you are unsatisfied with our answer, file a complaint to data protection authority in Czech Republic or in your country.
8.2. You have the right to object to the processing of your personal data in certain situations f.ex.for marketing purposes at any time. You can do so by contacting us here or by changing your email settings within your A4G account. Also email communications from A4G to you will contain an optout/unsubscribe option.
8.3. Know your rights! These include the right to know how your personal information is being used, access to the data itself, the right to alter it, transfer, restrict how we use it, or just have it all deleted. Simply contact us at firstname.lastname@example.org.
Depending on where you live, you may have additional privacy rights. For example, under EU laws you have the following additional rights:
● to access information we hold about you
● to request that we delete your personal information from our systém
● to ask us to rectify/correct your personal information if appropriate.
● to ask us to restrict processing of your data
● to transmit your data to another entity
● to lodge a complaint with a data protection authority. You can exercise these rights by contacting us f.ex. here or at email@example.com.
You may have additional privacy rights (see opposite).
8.4. If you have any concerns about your privacy please contact us first. If however you feel we have not dealt with your concern you can report this to your local data protection regulator or the Urad ochrany osobnich udaju ("UOOU") in Czech Republic.
10. INFORMATION WE COLLECT
10.1 When you register a A4G account with us, you will need to provide us:
(a) your username
(b) your email address
(c) a password (which is encrypted so that we don’t have access to it).
This information is necessary for us to provide you with A4G account requested by you. In your A4G account settings you can also set your Nickname, Name or Surname, and your geographical location. This information will be protected by your A4G account password. You are responsible for keeping it safe - please don't share it with anyone.
10.2. We cannot and will not knowingly collect personal information about children under 16.
10.3. To register a A4G account, we will ask you for and collect some basic personal information, including username and email. We need this to provide you A4G account. Once more time, Please keep your A4G account password safe.
10.4. When you use A4G services we may also collect the following information (how we use it is described later in this document):
- Technical details about devices which you use to access A4G services, including: Internet and/or network connection (including your IP address); mobile device identifiers; your operating system, browser type or other software; your hardware details; or other technical details provided by your web browser. This is technical data about our users and their actions and patterns, which does not provide personal information;
- Details of your use of A4G services including, but not limited to: metrics information about when and how you use A4G services (such as what game(s) you are playing, your current status, your interactions with others); traffic data; your geographical location; your purchase history; emails received; and links accessed; your preferences and choices such as subscriptions, preferred language and currency; your friend lists on A4G your communication via chat, game reviews, published posts on forum and other A4G Services
- Other information required in order to help you with any queries/support you may need assistance with via the A4G forums or customer support, including communications with you.
- Limited payment processing information, including as applicable your credit card number, name and email address (on a hashed / anonymised basis as applicable), payment methods, payment engine and transaction type; fraud risk score
- If you use Facebook Connect we may also collect limited information through Facebook Connect such as your Facebook ID, avatar, e-mail and friend list;
- Any other information which you supply us via our services
10.5. A quick word about bug reports and crash logs: A4G software will generate bug or crash reports regarding A4G services – these reports will not mention your personal information. You can decide whether to submit these reports to A4G team automatically. If you manually submit bug or crash reports to us, or if we contact you asking for feedback regarding crash or bug reports, then we may store them alongside your personal information.
10.6. A quick word about payment details (if/when you use them in A4G Services): this is a matter for the relevant payment method/platform/processor. We process only limited payment processing information on a hashed/anonymised basis as applicable. If you make any purchases within A4G Services, then we are notified by the payment processor once a transaction takes place and of course we make sure you receive your purchased item, but we will not receive any of your actual payment details
11. HOW WE COLLECT INFORMATION FROM YOU
11.1. We may collect, process and use information about you in the following ways (either directly or via our Partners as explained above):
(a) information you give us via A4G services
(b) information given when you contact us or report a problem with A4G services
(c) we may also ask you to complete surveys that we use for research purposes, although you don't have to respond to them. We may collect this information via A4G services or trusted third parties connected with us for optional things like surveys or polls.
11.2. Facebook Connect. When you register to A4G Services via Facebook Connect (of course, its optional), Facebook will provide us with certain information about you such as your Facebook ID, avatar, e-mail, gender, location and friend list. Data is gathered strictly in accordance with the social network(s)’ terms and conditions, so check your privacy settings on Facebook.
11.3. A4G Connect. When you use our cool and optional feature A4G Connect we will be retrieving limited information from your Steam account. This function now is under development…Stay tuned, comming soon!
We will collect the information ourselves or via third parties when it comes to optional things like surveys, A4G Connect or authentication services like Facebook Connect.
12. WHY DO WE USE YOUR DATA? (LEGAL GROUNDS FOR DATA PROCESSING)
12.1. When we process information about you, we do so as necessary to provide A4G services you use (i.e. to perform agreement between us), meet our legal obligations (f.ex. tax, accounting) or for other reasons that are important for us like informing you about games we distribute and making sure our marketing is relevant for you, protecting the security of our websites and systems, protecting you against fraud or other described in the “How we use your data”). When we rely on the reasons that are important for us, we consider and balance any potential impact on you and your rights. For other purposes we will ask for your consent and you will be entitled to withdraw this consent any time, with no impact on the validity of the processing before your consent has been withdrawn.
12.2. When we transfer your data outside of the European Economic Area, we do so on the basis of a variety of legal mechanisms, as described in “Trusted Partners”.
In essence, we process your data to provide you with A4G services, to meet our legal obligations and for other reasons that are important for like informing you about our games and ensuring security of our website. In other cases, we will ask for your consent in advance and you will always have the right to withdraw it anytime you like.
13. HOW WE HANDLE YOUR INFORMATION
13.1. All information you provide to us is stored on our secure servers or those of our trusted partner services. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage
All information you provide to us is stored either on our secure servers or those of our trusted partners
- we will keep information that is associated with your A4G account for the duration of your agreement for the access to A4G Services (i.e. until you close your A4G account). If you choose to close your A4G account, limited data that we collect about you may still be retained for tax, legal and accounting purposes;
- if you don’t have a A4G account and contact us we will retain correspondence with you as long as necessary to help you out and then for the period necessary for legal or accountability purposes;
- information that you post on our public forums and your game reviews will be retained until you decide that it should be removed as well. We don’t want to interfere with your posts and expressions without your permission.
In general, we’ll store your data until you close your A4G account. If you do, we may still use limited information about you for tax, legal or accounting purposes.
14. HOW DO WE USE YOUR INFORMATION
14.1. We will use the above information in the following ways:
- to carry out our obligations arising from any contracts between you and us, like providing access to your A4G account, providing you with the games and technical support and in general allowing to use A4G Services and its functionalities when you choose to do so f. ex. your A4G user profile, chat, forum or cloud saving and crossplay services in A4G ecomerce.
- to ensure that A4G services are presented in the most effective manner for you and for your computer or other device from which you access A4G services.
- to provide you with information, products or services that you request from us and which we feel may interest you - in particular, we may send you newsletters or emails about A4G services, special and occasional offers like a welcome offer or provide you with ads, offers and product recommendations on the basis of your purchases or activity on our and third party websites and services (of course, it’s optional);
- to evaluate the effectiveness of our marketing actions and improve the quality of our marketing;
- to notify you about changes to A4G services and our legal documents.
- to improve or modify A4G services, f.ex. based on which games you like, how you play them, reported problems, your suggestions or satisfaction surveys
- to improve or modify A4G services, for example based on which games you like more and how you play them.
- to calculate conversion rates and other elements of A4G performance.
- in connection with the services of our Partners, such as payment processors, located in and outside the European Union, but only to the extent necessary to provide those services.
- to provide you with optional functionalities such as A4G Connect or authentication via Facebook account.
- to create a universal user’s profile based on information about your use of A4G Services and other platforms (we’ll rely on data made available when you merge your A4G account with your account on other platforms) in order to make our Services even more interesting for you.
- to protect you from an unauthorized use of your account and against fraud
- for tax, legal and accounting purposes
- for the accountability purposes as defined by EU legislation (GDPR)
We will use your information to run A4G and keep improving it as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may have to share anonymised, nonpersonal information like operating system types in order to run A4G services.
14.2. Whenever we’re personalizing or targeting our marketing communications, offers and adverts, we may profile your personal information. We do not make however automated decisions (f.ex. via algorithms) that could affect your legal situation. If you decide that you no longer want to receive personalized offers, product recommendations from us, or no advertising news at all, you can object to this at any time. You can also choose whether to receive marketing communication from us, including personalized and targeted marketing emails by managing subscriptions on your A4G Account Subscription page, following the link "unsubscribe" attached to our marketing emails or just contacting us directly via email: firstname.lastname@example.org.
14.3. Non-personal data. We might process some aggregated and general non-personal data on user behaviour (e.g. sales per region, number of support tickets) and share it with third party partners who work with us to provide A4G services to you (for example, with games developers/publishers selling games on A4G or with payment providers) in order to support, improve or amend A4G services or to help them to improve their products, which you have bought. We may also share nonpersonal information with data analysis services to help us run A4G.
15. OTHER STUFF
15.1. Please be aware that we are subject to various laws and we may be required to release personal information to comply with law enforcement or other legal requirements.
We might be required to comply with law enforcement requests to release personal information.
Regardless of any reorganisations, acquisitions, etc., your personal information will be protected the same way as it is right now. No Fear!
Feel free to contact us if you have any questions with regards to the changes.
16.3. If you don't agree to those changes (regardless of whether you email us), then unfortunately we must ask you to cease using A4G services. We're sorry we have to say that, but we hope you'll appreciate that for A4G services to work properly we need to have everyone using it under the same rules instead of different people having different rules. That's why we encourage you to get in contact if you have queries.
17. USER AGREEMENT
Sincerely Your A4G - Legal Team.