(LAST UPDATED ON: 5 JUNE 2019)
Radioactive Magic collects your personal information when you use the Radioactive Magic websites, videogames, mobile applications or other services (“Services”), including when you buy our products, or otherwise contact us. Generally, personal information is collected when (a) you use a Service, (b) you make a purchase within our Services, (d) you create user generated content, (e) you watch advertisements within our Services, (f) you sign up to a newsletter, (g) you contact Radioactive Magic customer service and during technical support sessions, (h) you enter into a contest or sweepstake, (i) you chat with other users of the Services, (j) you wish to participate in a beta or otherwise download a patch or a demo and (k) you share or otherwise contribute to our social media channels and other community websites.
We use this personal information to: provide you the products or Services you have requested; to send you information about our products or Services; when you agree, to send you marketing information and to respond to your correspondence;
Whatever the activity may be, we will only collect personal information to the extent deemed reasonably necessary to fulfil your requests and our legitimate business objectives.
IMPORTANT INFORMATION AND WHO WE ARE
Full name of legal entity: Radioactive Magic
Email address: firstname.lastname@example.org
TYPES OF INFORMATION COLLECTED
In order to better provide you with our numerous services, we collect two types of information about our users: Personally Identifiable Information ( “PII”) and Non-Personally Identifiable Information (“Non-PII”). Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customised experience while using our site. PII means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It refers to information that lets us know the specifics of who you are.
Information you provide to us
When you engage in certain activities on the RadioactiveMagic.com, such as ordering a product or service, entering a contest or sweepstakes, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities; however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other PII (“Identity Data”). When ordering products or services on the site, you may be asked to provide a credit card number (“Financial Data”). Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
Information we collect about you
We gather certain information about you based upon where you visit on our site in several ways. This information is compiled and analysed on both a personal and an aggregated basis. This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and/or your Internet Protocol (“IP”) address (“Technical Data”).
A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
Information we receive from other sources
PURPOSE FOR WHICH WE PROCESS PII
We will only process your PII, in accordance with applicable law, for the following purposes:
handling and fulfilling your orders, if you request goods or services from us. This may also include processing of information that we receive from third parties, for example, address data to verify your correct address – Identity Data and Financial Data;
obtaining payment from you, if you purchase any of our goods and/or services – Identity Data and Financial Data;
enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions, as may be required, in order to fulfil your orders – Identity Data and Financial Data;
resolving any returns, refunds or disputes, if you lawfully exercise your rights or if you wish to dispute any part of our offering – Identity Data and Financial Data;
sending you administrative communications and notices – Identity Data;
sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you – Identity Data;
serving personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our sites, and other data obtained through the use of “cookies” placed on your devices. Please see our Cookie Statement below – Identity Data;
ensuring the security of your account and our business, preventing or detecting fraud or abuses of our site, for example, by requesting verification information in order to reset your account password – Identity Data and Technical Data;
developing and improving our products and services, enhance the operation of our site and statistically analyse site use, for example, by reviewing visits to our site and its various subpages, demand for specific goods and services and User comments– Identity Data and Technical Data;
to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law– Identity Data, Financial Data and Technical Data;
your request for content, goods or services necessitating steps including processing of your PII to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract; and
legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights. We will rely on this legal ground in relation to the processing set out in paragraphs above, in which we have a legitimate interest; and
compliance with a legal obligation to which we are subject, such as, for example, the processing for the purposes set out above.
We use different methods to collect data from and about you including through:
Direct Interactions: We collect PII about you when you voluntarily provide it to us. You provide certain PII (mostly Identity Data) to us when you (a) register for our services and register your e-mail address with us; (b) enter sweepstakes or contests sponsored by us or one of our partners; (c) sign up for special offers from selected third parties; (d) send e-mail messages, submit forms, or transmit other information by telephone or letter; or (e) submit your credit card or other payment information when ordering and purchasing products and services on our site. We may also collect information from you at other points on our site that state that such information is being collected.
Automated Technologies or Interactions: In addition, we may also collect certain other Technical Data (some of which is Non-PII). This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our site, and to gather demographic information.
Third Parties or Publicly available sources: Our third-party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our site.
In addition of identity Data we may collect demographic information such as your age, gender, favourite styles of gaming and the device you own.
RELEASE OF INFORMATION
We do not sell, trade, or rent your PII to others. We do provide some of our services through contractual arrangements with affiliates, services providers, partners, and other third parties. We and our service partners use your PII to operate our sites and to deliver their services. Where we wish to disclose or are compelled to disclose your PII to third parties this will only take place in accordance with applicable laws and for the purposes listed above. These scenarios include disclosure:
to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our data centre provider for the safe keeping of your PII, web hosting provider through which your PII may be collected, identity verification partners in order to verify your identity against public databases, logistics partners for delivery of products you have ordered, bank to process you credit card information where you have purchased something from us;
to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;
to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
to analytics and search engine providers (including Google Analytics and Unity Analytics) that assist us in the improvement and optimisation of the Site and services. Your PII is generally shared in a form that does not directly identify you;
third party analytics providers that assist us in establishing trends amongst our users based on the information you provide to us and generating associated content (for example, news articles and/or social media posts);
to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your PII will be permanently transferred to a successor company;
to public authorities where we are required by law to do so; and
to any other third party where you have provided your consent.
We will encourage our service partners to adopt and post privacy policies. However, the use of your PII by our service partners is governed by the privacy policies of those service partners and is not subject to our control.
We may also provide Non-PII about our customers’ sales, traffic patterns, and related site information to third-party advertisers, but these statistics do not include any PII.
We will only share your PII we collect from you through the Services with third parties as described in this Policy or otherwise as detailed at the time of collection. For example, we may share your PII as follows:
With vendors, consultants, and/or other service providers (“Service Providers”) who are engaged by or working with us in connection with the operation of the Services and/or the promotion of Radioactive Magic products and who need access to such information to carry out their work;
With other Users of the Services as described herein; and
With promotional partners to send you coupons, promotions, rewards, awards and advertisements you request.
To the extent that third parties have access to your PII, whenever possible, we will request that they will follow practices that are at least as restrictive as the practices described in this Policy;
Console Accounts/ Social Networks : By playing an Radioactive Magic game through a social network or other third party platform or service, or by connecting to a third party account, network, platform or service via one of our products and/or Services, you are authorising Radioactive Magic to (1) collect, store, and use, in accordance with this Policy, any and all information that you agreed that the console manufacturer, social network or other third party platform could provide to Radioactive Magic based on your settings on your console account, the third party social network or platform and (2) share any and all of your Personal Information with the console manufacturer, social network or other third party platform, through the third party platform’s Application Programming Interface (API). Your agreement to this takes place when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) one of our applications through the third party platform or service.
Online Events and Promotions: Your participation in online events and promotions may be conditional upon Radioactive Magic’s collection, use, storage, transmission and public display of statistical data (such as your scores, rankings and achievements) generated through your participation. This statistical data may include your PII.
You understand that when you use the Services, any information you post in any interactive areas of the Services, as well as any information you share with individuals through public or private groups or forums, as well as any information you share with individuals through the Services or through social network sites or other social feeds, will be available to other Users and in some cases may be publicly available. We recommend you be cautious about giving out PII to others or sharing PII in public or private online forums. Except to the extent required by applicable law, we are not responsible for the actions of third party service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.
INTERNATIONAL TRANSFER OF PII
We may transfer your PII to:
third parties in countries outside the country in which it was originally collected; and
within the Radioactive Magic group (which may also involve a transfer to a country outside the country in which it was originally collected),
for further processing in accordance with the purposes set out in paragraph 3 above.
In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means including:
transfers to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
for transfers to the US, if the entity is part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
RETENTION OF PII
Your PII will be retained until your last use or purchase of our services or goods and normally for a period of five years thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your PII that is no longer required for the purposes set out in this Policy. The retention of your PII will be subject to periodic review.
We may keep an anonymised form of your PII, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
DATA SUBJECT RIGHTS
Data protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their PII. Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their PII is not being processed in accordance with applicable law.
Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their PII. If you would like to make a SAR, i.e. a request for copies of the PII we hold about you, you may do so by writing to us with the contact details above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee.
Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete PII.
Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your PII at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your PII is essential.
Right to object to processing. You may, as permitted by applicable law, request that we stop processing your PII.
Right to erasure. You may request that we erase your PII and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your PII, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
Right to data portability. In certain circumstances, you may request that we transfer your PII TO YOU OR TO A THIRD PARTY in a structured, commonly used and machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your PII in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your PII. However, you do have the right to contact the relevant supervisory authority directly.
UPDATING AND CORRECTING INFORMATION
We believe you should have the ability to access and edit the PII that you have provided to us. You may also access and correct your personal information and privacy preferences by writing us using the contact details above.
Please include your name, address, and/or e-mail address when you contact us.
We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed (see above).
USER CHOICES ON COLLECTION AND USE OF INFORMATION
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may, from time to time, send you e-mails regarding our products and services. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only Radioactive Magic (or agents working on behalf of Radioactive Magic and under confidentiality agreements) will send you these direct mailings and only if you indicated that you have not opted out of receiving such marketing and, in relation to marketing from our partners, only if you have expressly opted-in to receiving marketing communications from third parties.
If you do not want to receive such mailings, contact us at any time to no longer receive such offers and mailings.
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our site may not work properly.
SECURITY OF INFORMATION
As described above, in order to most efficiently serve you, credit card transactions and order fulfilment are handled by established third-party banking, processing agents and distribution institutions. They receive the information needed to verify and authorise your credit card or other payment information and to process and ship your order.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
PRIVACY POLICIES OF THIRD-PARTY SITES
GUIDELINES FOR CHILDREN
Radioactive Magic follows the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children, in our online services and Apps that are directed to children. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the United States Federal Trade Commission’s website.
Radioactive Magic also implements technical and organisational measures to help protect children’s personal data in accordance with the new General Data Protection Regulation (GDPR). The GDPR is the new European Union (EU) data protection law that becomes effective on May 25, 2018.
In our Apps directed to children users, we may collect pseudonymised information which includes persistent identifiers such as a transaction ID to verify purchases, which is encrypted upon collection. This information is collected solely for the purpose of providing functionality and support for our internal operations and optimising our users’ game experience.
Radioactive Magic does not allow any personal information to be linked to the Children’s PII. If we learn that we have collected any personal information from Children, we will delete that personal information as quickly as possible.
The Apps may contain advertisements or advertising messages about Radioactive Magic or third party products and services. In any case, Radioactive Magic does not permit behaviourally-targeted advertising to children in the Apps or in the Platforms where user is under the age of 13.
AS FAR AS IS PERMITTED BY APPLICABLE LEGISLATION, Radioactive Magic DECLINES ANY RESPONSIBILITY REGARDING ANY ACTIVITIES WHICH MAY BE CONDUCTED BY CHILDREN WITHOUT THE PERMISSION OF THEIR PARENTS OR LEGAL GUARDIANS.
IF YOU ARE A PARENT OR LEGAL GUARDIAN AND YOU GIVE YOUR PERMISSION FOR YOUR CHILD TO REGISTER FOR ONE OR OTHER OF THE SERVICES, YOU THEREBY AGREE TO THE TERMS RELATING TO USE OF THE SERVICES BY YOUR CHILD.