Privacy policy

This Privacy Policy was last updated on December 23, 2020

Introduction


CloverCreek Entertainment Oy (hereinafter referred to as “CloverCreek Ent”, “we”, “our” or “us”) is a game development studio, business ID number: 2873351-3.

This Privacy Policy governs how your personal data (hereinafter referred to as “Personal Information”) is collected, used, and managed by CloverCreek Ent. Personal Information is information, which on its own or in combination with other data allows identifying a given User (e.g. name, email address, or billing information). Our Privacy Policy respects users’ privacy, adheres to applicable privacy laws, and is fully transparent.

Please note that this Privacy Policy neither applies to nor regulate activities conducted by Users on third parties’ websites and services. We do not bear any responsibility for whatever privacy matters Users have with third parties. These include external sites where you purchase, download, play our games, gaming platforms or servers not owned or operated by CloverCreek Ent. Furthermore, we strongly recommend you not to share any Personal Information on our pages hosted on social media sites or applications (e.g., Facebook, Twitter, Twitch, Google, Instagram, YouTube, Reddit) in public comment sections and other publicly-visible places, as we are not responsible for the protection of any Personal Information which was shared publicly by Users.

If you have any questions on the terms and conditions of this Privacy Policy, please contact our Data Privacy Officer at: corp@clovercreekent.com

By using our website, social media pages, and games (hereinafter referred to as “Services”), you are agreeing to the terms of this Privacy Policy. Please read them carefully. If you do not agree to this Privacy Policy, please do not use any of our Services. We are committed to handling and protecting your Personal Information very responsibly and in accordance with applicable data protection and privacy laws.

Which personal data we collect from you and how?

We collect 3 types of User data:

1) Personal Information which you provide to us voluntarily via direct interaction or registration within our Services (first-party data).

You do not need to provide any Personal Information to us to access our websites, but if you wish to communicate with us through the Services, receive informational materials from us (e.g. newsletters), or receive prizes from any ruffles and contests organized by CloverCreek Ent we can ask you to provide some of your Personal Information, depending on the activity:

- Full name

- Email address

- Phone number

- Physical mailing address

2) Information provided by third-party services which collect it when you interact with our website, ads and social media pages (third-party data).

We collect User information through trusted third-party services (e.g. Google Analytics, Facebook Ads) to provide and improve our Services. In addition, online platforms where we publish and sell our products (e.g. Steam) share with us some of Users’ personal data to improve gameplay and permit us to contact Users for appropriate purposes. If we remove our products from those platforms, these platforms may transfer personal data to us, if necessary, to support your continued gameplay.

All these third-party services comply with the General Data Protection Regulation (GDPR). The following information can be collected only when you in any way interact with our website and/or our ads and/or our social media pages:

- Gender

- Age

- Language preferences

- IP-address and location

- Operating system and browser you are using while visiting our website

- Visiting time and visits history

- Referring website

- Your behavior on our website

- account ID (e.g. on Steam);

- display name (e.g. on Steam);

- friends list if Users’ friends also have purchased the same product (e.g. on Steam).

3) Anonymous information about your gameplay choices and game progression which we collect through a third-party analytics software that is integrated in our games (e.g. Ascended Realms).

This information may include, for example, Talents you research, Buildings you build, Heroes you recruit, Tiers and Chapters you play, and other game-related anonymous data.

Why do we collect your personal information?

We collect your personal information for the following purposes:

- To allow you to communicate with us through our Services

- To provide you with customer service

- To allow you to receive prizes after participating in our raffles and contests

- To inform you about any news, promotions and special offers which could be beneficial for you

- To analyze the effectiveness of our advertising campaigns

- To learn your preferences in order to improve your experience of interacting with our Services

- To improve our games.

Who do we share your personal data with?

We use trusted third-party services (so-called data processors) for storing and managing your information digitally:

- Yandex cloud services (storing documents containing Personal Information – e.g. a list of several Users’ home addresses for sending the raffles prizes)

- Yandex email services (communication with Users who contacted us by email or through contact forms provided on our websites)

- MailChimp (email marketing campaigns)

We may also share your Personal Information with government and public authorities upon their official request.

How you can manage your personal information?

At any time:

- You may ask us to modify/delete all your Personal Information that we store on any resources. We shall erase all your personal information within 30 days following your request.

- You may change your choices/preferences for newsletter subscription (by contacting us directly or clicking on Unsubscribe button at the bottom of our emails).

Children's policy

CloverCreek Ent does not intentionally or knowingly collect Personal Information from children under 13 through its Services. If you believe that we have inadvertently collected your child’s Personal Information, please contact us and we will delete this information from our resources.

User's rights

All our users have full rights:

- to be informed:

You have the right to be informed about the Data Protection Officer’s identity, the contact data of the Data Protection Officer, the processing purposes and the legal basis, any legitimate interests pursued, the recipients when transmitting personal data, and any intention to transfer personal data to third countries. In addition, you have the right to be informed about the duration of storage, the rights of the data subject, the ability to withdraw consent, the right to lodge a complaint with the authorities and whether the provision of personal data is a statutory or contractual requirement.

- to access information:

You have the right to obtain the following, from the data controller (for free, or for a reasonable fee in case further copies of information are requested):

 - Confirmation of whether or not personal data concerning you is being processed;

 -Where personal data concerning you is being processed, a copy of your personal information;

 -Where personal data concerning you is being processed, other additional information as follows:

 -Purpose(s) of the processing;

 -Categories of personal data;

 -Any recipient(s) of the personal data to whom the personal data has or will be disclosed, in particular recipients in third countries or international organisations and information about appropriate safeguards;

 -The retention period or, if that is not possible, the criteria used to determine the retention period;

 -The existence of the following rights

    i. Right to rectification

    ii. Right to erasure

    iii. Right to restrict processing

    iv. Right to object – and to request these from the controller.

 - The right to lodge a complaint with a supervisory authority (in Ireland this is the Data Protection Commissioner, whose contact details are on page 14 of this guide);

 - Where personal data is not collected from the data subject, any available information as to their source;

 - The existence of automated decision making, including profiling and meaningful information about how decisions are made, the significance and the consequences of processing.

- to rectification:

If your personal data is inaccurate, you have the right to have the data rectified, by the controller, without undue delay. If your personal data is incomplete, you have the right to have data completed, including by means of providing supplementary information.

- to erasure:

You have the right to have your data erased, without undue delay, by the data controller, if:

 -your personal data is no longer necessary in relation to the purpose for which it was collected or processed;

 - if you withdraw your consent to the processing and there is no other lawful basis for processing the data;

 - your personal data have to be erased in order to comply with a legal obligation;

 - your personal data has been unlawfully processed;

 - you object to the processing and your personal data is being processed for direct marketing purposes.

- to data portability:

In some circumstances, you may be entitled to obtain your personal data from a data controller in a format that makes it easier to reuse your information in another context, and to transmit this data to another data controller of your choosing without hindrance. This is referred to as the right to data portability.

- to object to processing of personal data:

You have the right to object to certain types of processing of your personal data where this processing is carried out in connection with tasks in the public interest, or under official authority, or in the legitimate interests of others. You also have the right to object to processing of your personal data where the processing relates to direct marketing. You may also object to processing of your personal data for research purposes.

- of restrictions:

You have a limited right of restriction of processing of your personal data by a data controller. Where processing of your data is restricted, it can be stored by the data controller, but most other processing actions, such as deletion, will require your permission.

- in relation to automated decision making, including profiling:

You have the right to not to be subject to a decision based solely on automated processing. Processing is “automated” where it is carried out without human intervention and where it produces legal effects or significantly affects you.

May this Privacy policy be changed?


We reserve the right to make modifications to this Privacy Policy from time to time. We will inform you about any changes with a timely notice – by sending a newsletter, making an updated privacy policy available on our website and by other possible means of communication.  Your continued use of the Services after the updated Privacy Policy is made available on our websites will mean that you accept that revised version.

How to contact us


If you have any questions about this Privacy Policy or requests regarding your Personal Information, please contact us by emailing at corp@clovercreekent.com

The controller of the processing of the personal information:

Tatiana Bartceva,
Chief Executive Officer
tatiana.bartceva@clovercreekent.com
+358466221170

Legal address:
CloverCreek Entertainment Oy
Leonkatu 21 A 36
00450 Helsinki
Finland