The terms “Easyportal”, “we”, “us”, “our” and “ours” when used in this Privacy Policy mean Easyportal Ltd, which includes any subsidiaries, divisions, branches or companies under common ownership or control of Easyportal Ltd. The terms “you”, “your” and “yours” when used in this Privacy Policy mean any user of our websites or services.
The term “Personal Data” refers to any information relating to an identified or identifiable natural person. GDPR Art. 4(1)(1)
1.Introduction to Privacy Policy
We are committed to the privacy and confidentiality of information provided by you to us. This Privacy Policy describes our current policies and practices in compliance with the General Data Protection Regulation (GDPR) with regard to Personal Data collected by us from you directly and/or through our websites, games and services. For the purposes of GDPR regulations Easyportal Ltd is the “data controller”.
Please note that by submitting Personal Data manually or in electronic form to us and/or by using our websites and/or services you give your consent that all Personal Data on each occasion that you submit may be processed by, and/or shared within the Easyportal Ltd, in the manner and for the purposes described in this Privacy Policy.
2.Notification of changes to this Privacy Policy
We are continually improving our methods of communication and adding new functionality and features to our websites and to our games and services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will notify you of the changes via this page. We encourage you to check this Privacy Policy frequently.
3.Data Protection Policy
We process gamers’ personal data to provide access to our online games, to develop new games and refine existing games to work better with different devices. This processing is necessary to fulfil our contract with gamers and is in our legitimate business interests to develop new games and refine existing ones to work better with different devices.
We also process personal data to protect the security and integrity of our databases, particularly fraud prevention and take precautions against legal liability. This processing is in our legitimate business interests in protecting the security and integrity of our games and compliance with potential legal obligations.
It is in our legitimate interests to keep our games up to date with new technologies and provide a good user experience. It is also in our legitimate interests to protect ourselves and other gamers from fraudulent activity.
We collect the following data from you –
Data you provide us.
•Name
•Contact information (such email address, city and country of residence, skype or vk id)
•Player username and password
•Your messages to the Service (such as chat logs and player support tickets)
•Other data you choose to give us (such as data to identify a lost account)
Data we collect automatically.
•Data about your account and game progress
•Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
•Data about your device, such as device name and operating system, browser type and language
•Data we collect with cookies and similar technologies (see more below)
•General location data
•Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service
Why we collect your data
To make the Service work.
To perform the contract, we process data necessary to
•Create accounts and allow you to play our games and use our Service
•Operate the Service
•Verify and confirm payments
•Provide and deliver products and services you request
•Send you Service-related communications
To make the Service more suitable for our players.
To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to
•Update and develop player profiles
•Develop and improve the Service and player experience
•Manage our relationship with you
•Provide social features as part of the Service
•Customize your Service experience
•Respond to your comments and questions and provide player support
•Provide you Easyportal offers in the Service as well as in other websites and services, and by email
•Send you related information, such as updates, security alerts, and support messages
•Enable you to communicate with other players
To keep the Service safe and fair.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
•Analyze and monitor use of the Service and its social features
•Moderate chats either automatically or manually
•Take action against fraudulent or misbehaving players
To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
We do not collect special category data, that is information about heath, race, religion, political beliefs or sexual orientation.
We recognize that there could be such information in in-game messages but we do not encourage this.
We currently hold gamer records indefinitely but we are moving to a seven year retention period to coincide with accounting requirements. We will be deleting any personally identifiable data, such as IP addresses, email addresses etc if an account has not been used for a period of seven years.
4.Anonymous data collected through our websites
In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our websites. For example, we use technology to track which pages of our websites our visitors view. We also use technology to determine which web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our websites.
We use this anonymous data to improve the content and functionality of our websites and our e-mail updates, to better understand our customers and visitors, and to improve the services we offer.
5.Cookies
A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Easyportal uses Cookies to collect information about a user’s visits and to enhance the user’s experience when visiting the Websites and games operated by Easyportal. A cookie can be used to store information like your password, or the fact that you have already registered. This allows us to speed up your future activities, saving the time you would normally spend entering information such as your password or registration information.
Cookies can be refused by you by activating the appropriate settings on your web browser. By doing this, please be aware that you may be unable to access certain parts of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our websites.
6.IP Address
An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. We may track your IP address for, security, site tracking, administration of our websites or services, to prevent abuse of our game servers, or to gather broad demographic information such as determining how many of our visitors are from outside of the UK.
We may also perform IP lookups to determine which domain you are coming from (i.e: aol.com, yourcompany.com) to more accurately gauge our users’ demographics.
7.Disclosure of your Personal Data
We do not share with, nor sell nor distribute your Personal Data to unrelated third parties, except under these limited circumstances:
•We may share various details about you within our business, to advisers and other agents in order to provide you with the specific service you require.
•Personal Data may occasionally be transferred to third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented or otherwise in accordance with this Privacy Policy. This may include, but is not limited to fulfilling purchase orders or prizes, processing mailings, or storing data.
•We will not share or disclose your Personal Data to any unrelated third parties for their own marketing purposes unless you have given us your consent to do so.
•We may share or transfer the information in our databases to comply with a legal or regulatory requirement, for the administration of justice, interacting with anti-fraud databases, to protect the security or integrity of our databases or our websites or services, to take precautions against legal liability, protect and defend the rights or property of Easyportal or its licensees or licensors, protect the personal safety or interests of our employees, users of our products or services, enforce the terms and conditions for the supply of our products and services (including the Terms of Use ) or any applicable license agreements or in the event of our sale, merger, reorganization, transfer of business, dissolution or similar event.
•We may disclose your account information to a third-party that alleges that you have infringed their intellectual property rights, subject to reasonable verification of such claims.
•If we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
•Easyportal may provide online in-game chat rooms, in-game mail systems and forums to users. Any information that is disclosed in these chat rooms and forums is public information and users should exercise caution when deciding to disclose personal information in such chat rooms, in-game mail and forums. If you voluntarily disclose information in a public area of the Easyportal websites and/or services, such as a forums post or text chat room, that information may be collected and used by a third-party to send you unsolicited messages, advertisements or for other purposes. We do not control the actions of these third parties in such public areas. If you disclose information in such a public area, you do so at your own risk.
•Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.
8.Children
Easyportal does not direct its websites, games, game engines, or applications to children (usually considered to be under the age of 18, depending on the country where you reside). We also do not intentionally collect personal information from children through our websites, games, game engines, or applications. If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us at info@easyportalltd.com or “Support” section and we will delete the information from our records.
9.Data Integrity and Security
We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our websites and computer systems, aim to protect the loss, misuse or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy. Although we will use reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Accordingly, we assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.
10.Links to other websites
Our websites and services may contain hyperlinks to websites that are not operated by us. Any such hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.
Our websites contain hyperlinks to other pages on our websites. We may use technology to track how often these links are used and which pages on our websites our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.
11.Transfer of Data Abroad
We may transfer and store your Personal Data between our offices and third party processors which may be located outside the EEA. Where your Personal Data is transferred and stored outside the EEA we will ensure that the recipient agrees to keep your information confidential and hold it securely in accordance with the requirements of the GDPR.
By providing us with your Personal Data, you consent to the processing, transfer and storage of your Personal Data as set out in this section.
12.Unsubscribe
We hope you will be delighted with our services. If you no longer wish to receive information from us and want to be removed from our mailing list please, click the Unsubscribe link which may be found at the end of any marketing or promotional communications we send to you. The Unsubscribe link will give you the opportunity to withdraw your consent to receiving such communications in the future. Remember that by stopping the information that you receive from us about our products and services may not benefit you. For example, you may not hear about promotions we are running or additions to our service.
13.Governing Law
This Privacy Policy forms part of our websites terms and conditions for the supply of our products and services (including the Terms of Use) and as such shall be governed by and construed in accordance with the laws of England. You agree to submit any dispute arising out of your use of our websites or service to the exclusive jurisdiction of the courts of England.
14.Feedback
We welcome comments about this Privacy Policy. If you have any questions about this Privacy Policy, or any part of our service, you may contact us by emailing info@easyportalltd.com.
Visiting Easyportal Internet websites and using our on-line services indicates your acceptance of our Privacy Policy. If you do not accept this Privacy Policy, please do not visit our Internet websites or use our on-line services.
15.Banned Gamers
If you have been banned from the game, we have taken action to ban you from our game to prevent fraud and stop anti-social behavior in accordance with our terms and conditions.
This is in the legitimate interests of Easyportal and to comply with a legal obligation around fraud prevention which is in our legitimate interests to protect ourselves and other gamers from fraudulent and anti-social activity.
If you have been banned from the Game then the following shall also apply.
We will retain an encrypted version of your email address for the sole purpose of preventing you from creating a new gaming account. We will retain no access to the email address and it can therefore not be used for any other purpose.
If your behavior has resulted in a permanent ban from our game, then this information will be held indefinitely as we need to retain the information to enforce the ban.
16.Your data protection rights
You have the right to ask for a copy of the personal data we hold that relates to you. If you think that information about you which we hold is incorrect or misleading you have the right to have the information corrected provided you can demonstrate that it is incorrect. You can also request the erasure of personal data relating to you in certain circumstances, where we do not require it to meet a legal obligation. You have the right to object to processing on the grounds that it causes you damage or distress and the right to take away a copy of your personal data in electronic format in certain circumstances.
We do not rely on consent as a basis for processing. We provide this privacy notice which explains our use of personal data and the grounds we rely on.
If you are unhappy about the way we use your personal data or the way in which we respond to your request to exercise your data protection rights, you can contact Data Protection Coordination at Easyportal Ltd at info@easyportalltd.com.
All the personal data we hold is supplied ultimately by our gamers. Some of it may come to us indirectly from Google play, Apple i-Tunes, Steam, Microsoft store and other providers of leads. We obtain very limited personal data from third parties. Most of the personal data we hold is provided directly by you when you create an online account.
There is automated decision making in the gaming system. Your ability to purchase game in-game currency is limited depending on the time you have spent in the game, this is for fraud prevention purposes. We also have automatic lock out on accounts from shared IP addresses in line with our game rules to prevent players using multiple accounts.
CONTACT US
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us at the email address below.
Name of the controller: Easyportal Ltd
Address: Suite 7070 128 Aldersgate Street, Barbican, London, United Kingdom, EC1A 4AE