Event Horizon Studios Srl, an Italian corporation with registered and business offices in Via Caboto 18/A, 10129, Turin, Italy (Event Horizon Studios) respects your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you may understand the ways in which we do use the information you transmit when accessing and playing one of our Games (hereinafter the “Game”, “Games” or if the game is mentioned in connection with a website or social service, “Service” or “Services”).
Please note that your access and/or playing of the Game constitutes your acceptance of this Privacy Policy as well as our Terms of Use.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY PLEASE DO NOT ACCESS AND/OR PLAY THE GAME.
Event Horizon Studios processes your Personal Data according to EU GDPR.
For this Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure.
Event Horizon Studios will be the controller of your Personal Data processed in connection with the Services.
1. What Personal Data Do We Collect From You?
We – as the Data Controller – collect Personal Data about you when you provide such information directly to us, when third parties such as our partners and service providers – Oculus Store included – provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
1.2 Information we collect directly from you:
We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
1.2.1 – Information provided by you when using a Game:
- Username;
- Language;
- Oculus userID;
- Facebook Username;
- Friends on Oculus.
1.2.2 – Information that may be provided by you when you contact us for support:
- Your name;
- Your email address;
- Any further personal information you may write in the text box.
1.2.3 – User-generated content and information hosted and displayed in our Online Services
When using our Online Services, you may decide to post information that may or may not contain personal data (“User Content”), in accordance with the rules of the relevant Online Service (where this functionality may be available). Similarly, when using some of our Games or other Online Services (where this functionality is provided by us) you may decide to post certain content such as leaderboard information and messages to other users, in accordance with the terms of use applicable for the relevant Online Service (“Leaderboards”).
We cannot and do not control the wider dissemination via the public internet of personal data that you may choose to post, or make available, in User Content or Leaderboards.
1.3 Information we receive from third party sources:
If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g. Facebook Connect), or if you share content from our Services through a third party social media service, the third party service may send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing.
The information we receive will depend on the policies and your account settings with the third party service.
1.4 Information we automatically collect when you use our Games:
Some Personal Data is automatically collected when you use our Games, such as the following:
We may collect technical information about your use of our Games through the use of tracking technologies and analytics.
Personal data we may collect in this way includes the following:
- Your IP address and MAC address;
- Your user/account ID with us;
- Device country;
- Time, date and install source of your Game download/usage;
- Session start, duration and end timings;
- Identifying information about crashes and defects;
- Device information (e.g. device type, device unique ID and browser);
- Session results, progress and timings;
- System, browser and device settings and information (including model and operating system of your device, device properties such as orientation, Games played, country, language and locale settings);
- Application activity
This also includes the use of “cookies” and similar technologies.
2. Why we collect information from you?
2.1 – to provide the Online Services to you.
We will process information about you (including the Submitted Information and certain Analytics information) to deliver our Online Services to you under the terms of use agreed between us.
The processing of information in this way is necessary, for example, for us to record your progress and current status within an Online Service such as a Game, and to ensure the Online Services deliver the features promised and function 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), except for our processing of weight data you may choose to submit to us (as further detailed below).
No personal data, regarding the Games, will be directly managed and store by use.
2.2 – To respond to your enquiries and requests for support.
We may process certain of your Online Services Information (including your Contact Information and certain other Online Services 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 relevant Online Service) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.
2.3 – To help us to improve the Online Services and help us fix any problems.
We may process information about you so that we can analyze and improve our Online Services and also for us to develop new Online Services or new parts thereof.
This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Games and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Online Services.
2.4 – To help us to understand your usage of the Online Services
We may process information to understand how users use our Online Services, and to compile statistical reports regarding that activity, as well as understanding how users progress within a particular Online Service such as a Game. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems and to improve our future products and services.
2.5 – To prevent and punish frauds or illegal or harmful actions
We will finally process information according to our legitimate interests to protect against or deter fraudulent, illegal or harmful actions of the users and third parties.
3. How and With Whom Do We Share Your Data?
We share Personal Data with third party service providers and processors who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service.
These parties include:
- Fraud prevention service providers
- Ad networks
- Analytics service providers
- Staff augmentation and contract personnel
- Hosting service providers
- Software developers
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our terms of service, prevent harmful or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets.
You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
4. How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us.
5. What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.
However, since the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted through our Online Services; the sharing of your personal information with us and any transmission is at your own risk.
6. What about personal data of Children?
As noted in the Terms of Use here, we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please DO NOT attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at privacy@eventhorizonschool.com.
7. What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@eventhorizonschool.com.
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law.
In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
– Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
– Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
– Erasure: You can request that we erase your Personal Data from our systems.
– Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
– Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
– Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
– Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
– Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
8. Where are the Personal Data stored?
While our business offices are inside the European Union (“EU”), the Services may be hosted and operated in the United States (“U.S.”). Laws in the U.S. may differ from the laws where you reside.
By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to a service provider in the U.S. and will be hosted on U.S. servers, and you authorize us to transfer, store and process your information to and in the U.S.
Where your personal data is transferred 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.
9. What If You Have Questions Regarding Your Personal Data?
If you have any questions about this Privacy Notice or our data practices generally, please contact us at privacy@eventhorizonschool.com