PRIVACY POLICY

 

Here at eRepublik Labs we care about your privacy and we respect your privacy rights.

By using the eRepublik Service (as defined below), you permit the collection and use of your personal information as outlined below and you signify your agreement to this Privacy Policy. If you do not agree with these terms, you should not use the eRepublik Service.

  1. ABOUT OUR PRIVACY POLICY

eRepublik Labs Limited of The Unit 4, Block A, Broomfield Business Park, Malahide, Co Dublin, K36 RF83, Ireland, registration no. 462101, VAT No. IE - 9693023K (“eRepublik Labs”,“we”,“us” and “our”) provides and operates the Twin Shooter Invaders Game, available for iOS and Android, all their sections (the “Game”) as well as the in-game profiles and any other areas of the Game not listed here, that will or may be created in the future (the “eRepublik Service”). The eRepublik Service is administered by ERPK LABS SRL of 39-41 Nicolae Filipescu street, 6th floor, 2nd District, Bucharest, Postal Code 020961, Romania, registered with the Romanian Trade Register under No. J40/6415/2009, having the Sole Registration No. 25622297, on our behalf.

  1. The eRepublik Service allows people to register as players on the Game in order to engage and participate in a variety of activities and use the functionalities made available on the eRepublik Service from time to time.
  2. This policy (together with our Terms and Conditions of Use http://policy.erepubliklabs.com/TwinShooter-TermsOfService and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
  1. How we Collect Information on the Game
  1. We only collect and use personal information of our users insofar as this is necessary to provide the eRepublik Service. We collect and process personal information only with the user's consent or in those cases in which the collection and processing of the personal information is permitted by law. When registering as a user of the eRepublik Service or during your time as a user of the eRepublik Service you will be asked to provide information to us. We will inform you at the time of collecting other information from you whether you must provide the information to use the eRepublik Service or whether the provision of information requested by us is optional. We will inform you at the time of collecting information from you whether the information that you provide to us will be accessible to other users of the eRepublik Service or by third parties so that you can decide whether to provide the information to us.
  2. We may collect and process the following data about you:
  1. if you contact us (including by email or post) we may keep a record of that correspondence and of the information contained in it;
  2. information that you submit in response to an in-game chat discussion, private messages or through any other in- game communication channels;
  3. the functionality that you use through the eRepublik Service, including your gameplay choices;
  4. details of financial transactions you carry out through the eRepublik Service; and
  5. details of your visits to the eRepublik Service including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  1. Persons under 16 years of age are not entitled to register on the eRepublik Service. If you are between 16 and 18 years of age you agree that you have made sure that you have brought this Privacy Policy to the attention of a parent or guardian and that they have consented to you agreeing to this Privacy Policy and using the eRepublik Service (provided that the giving of such consent is not prohibited by law).
  1. USES MADE OF THE INFORMATION
  1. Our users may participate in the virtual community by interacting with other users on the eRepublik Service through discussion forums, alliances, in-game private messages or in-game chat channels. These can then be accessed and read by other users of the eRepublik Service. If you choose to be a registered user of the eRepublik Service, we will not display your personal information. Only in-game information will be available to other users, which is information that will allow users to evaluate your in-game activity and your eRepublik Service communications.
  2. We use information held about you in the following ways:

3.2.1 to ensure that content on the eRepublik Service is presented in the most effective manner for you and for your computer or device; such as hosting and displaying information, providing updates, developing, improving or expanding the eRepublik Service and addressing technical issues; The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR.

3.2.2 to provide you with information, products or services that you request from us. The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR.

3.2.3 to provide you with information which we believe may interest you (including products or services of any of our Partners) in case have consented to be contacted for such purposes including by interacting with advertising functionality in the eRepublik Service. The legal basis for the processing of personal information is Art. 6 para. 1 lit. a GDPR. For our mobile games we use advertising platforms that provide incentivized advertising (e.g. the user gets a reward by watching an ad). The legal basis for the processing of personal information is Art. 6 para. 1 lit. f GDPR. It is in our interest to provide advertising in our games and to give the user an opportunity to receive rewards in the game.

3.2.4 to carry out our obligations arising from any contracts entered into between you and us; to establish and maintain your account on the eRepublik Service and to protect the security of your account; The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR.

3.2.5 to deliver and maintain a high quality service; to provide customer support or to resolve customer issues; The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR.

3.2.6 to allow you to access the eRepublik Service and to participate in interactive features of our service, when you choose to do so; The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR.

3.2.7 to notify you about changes to our service, new features or new versions of the eRepublik Service, about new games or applications developed by our company or by our Partners; The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR and Art. 6 para. 1 lit. f GDPR. We have an interest in providing you with marketing information about our products and those of our partners.

3.2.8 for the purposes of compiling statistics and to generate and analyze information about our users so we can better understand them and how they use the eRepublik Service and draw trends and predictions based on this information; The legal basis for the processing of personal information is Art. 6 para. 1 lit. f GDPR. Our interest is in improving our services.

3.2.9 to determine whether you are in compliance with the eRepublik Service’s rules and to impose sanctions where necessary; The legal basis for the processing of personal information is Art. 6 para. 1 lit. f GDPR. Our interest is in improving our services and detecting fraud.

3.2.10 to process payments, if the case. The legal basis for the processing of personal information is Art. 6 para. 1 lit. b GDPR.

3.2.11 if you signed up for any newsletter, to contact you by email for news, promotional purposes or market research and that you may opt-out of by clicking an opt-out link located in such an email. The legal basis for the processing of personal information, in the case of existing consent, Art. 6 para. 1 lit. a GDPR.

The personal information will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user's email address will therefore be stored for as long as the subscription to the newsletter is active. The user may cancel the subscription to the newsletter at any time by clicking on the unsubscribe link at the end of each email newsletter.

  1. No personally identifiable information will be exported to third party websites or Apps, other than with your express authorisation in response to a request from a third party user. Please note that any authorisation that you give to a third party user to use your data is a matter for you and a third party user; we are not responsible for the manner in which you choose to allow them use your data.
  2. We may sell or licence the content you post on any area of eRepublik Service to personalize it and to identify/feature popular members. For example, we may promote the most popular active members. While we do not expect to transfer the complete member database to others, we use the nicknames and avatars in the database throughout our networks and to generate results for others, including, but not limited to, enabling users to contact each other and facilitating inter-user communications.
  1. Disclosure of your information to other people
  1. We do not disclose to any third party personal information that you provide to us unless we have your permission or the law permits or requires it.
  2. If you provide personal information to us you understand and agree that we may disclose your personal information to the following third parties:
  1. to the eRepublik Labs hosting provider: Amazon Inc. which uses servers located in the EU and in the US.

    2. You acknowledge that we may change the hosting provider at any time and any such change will be posted on the eRepublik Service by an amendment to this Privacy Policy. You consent to the transfer of your personal data to any new hosting provider’s servers. You may communicate any questions, comments or requests in relation to any change in hosting provider by emailing [email protected] or by post to ERPK LABS SRL, 39-41 Nicolae Filipescu street, 6th floor, 2nd District, Bucharest, Postal Code 020961, Romania.

  2. if you have indicated at registration, or at any time during your time as a user of the eRepublik Service that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, you consent to us sending you such offers or information. You may opt out of receiving such offers or change your preferences at any time by emailing [email protected];
  3. to companies that provide emailing services, with the sole purpose of sending you information about our services, including about any updates, new features or new versions of the eRepublik Service. These companies are prohibited from using your personally identifiable information for any other purpose than as mentioned in this article. You may opt out of receiving such offers or change your preferences at any time by emailing [email protected];
  4. to the prospective seller, buyer or assignee of any business or assets related to the eRepublik Service or all or part of eRepublik Labs Limited, ERPK LABS SRL, or any other member of our group of companies; and
  5. to a third party if we are under a duty to disclose or share your personal data with that third party in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of use _________ [insert link], or to protect the rights, property, or safety of our group of companies, eRepublik Labs, our customers, other registered users or others. This includes exchanging information with third parties for the purposes of fraud protection and credit risk reduction.
  6. to ERPK LABS SRL of 39-41 Nicolae Filipescu street, 6th floor, 2nd District, Bucharest, Postal Code 020961, Romania, registered with the Romanian Trade Register under No. J40/6415/2009, having the Sole Registration No. 2562229, the company administering the eRepublik Service.
  7. to advertisers enabling them to display relevant advertising.
  8. We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing at the time that we notify you. We will not transfer such information without your consent.
  9. to advertisers enabling them to display relevant advertising.
  10. to advertisers enabling them to display relevant advertising.
  11. to advertisers enabling them to display relevant advertising.
  12. to advertisers enabling them to display relevant advertising.
  1. We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing at the time that we notify you.
  2. We do not disclose personal information about you to other third parties (including advertisers or marketing companies) except those set out in this policy, but we may provide them with aggregate anonymised information about our users.  For example, we may inform them that 500 men aged under 30 have clicked on their advertisement displayed on our Game on any given day, or we might inform third parties regarding the number of unique users who visit our Game, etc. We may also use such aggregate anonymised information to help advertisers reach the kind of audience they want to target (for example, women in the southeast of Ireland) when displaying advertisements on our Game.  We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.  You agree to these practices.
  3. It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the European Economic Area (EEA).  This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA.  The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU but in these instances we will take steps to ensure that your privacy rights are respected. You agree that we may transfer your personal data on that basis.
  1. SECURITY AND CONTROL OF YOUR PERSONAL DATA
  1. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
  2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Game, you are responsible for keeping this password confidential.  We ask you not to share a password with anyone.  You are responsible for the security of your password and our Terms and Conditions of Use deal with this in more detail.
  3. Unfortunately, the transmission of information via the Internet is not completely secure.  Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.  You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
  4. You should be aware that when you voluntarily disclose personally identifiable information and agree to make that information public on our Game (e.g., user name, e-mail address) via personal messages, forums, or in other areas of our Game, that information, along with any substantive information disclosed in your communication, can be collected, correlated and used by third parties.  These third parties or other users may use your information to send you unsolicited messages.  Such activities are beyond our control.  Please do not post any personal information on our Game or in other areas that you wish to keep private.
  1. LINKS TO THIRD PARTY WEBSITES/APPLICATIONS
  1. Our Game may, from time to time, contain links to and from the websites/applications of our partner networks, advertisers and affiliates as well as third party websites/applications to which we have no affiliation.  If you follow a link to any of these websites/applications, please note that these websites/applications have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies or for the activities on those websites/applications.  
  1. IP ADDRESSES  AND OTHER DEVICE INFORMATION
  1. We may collect information about your device including (where available) your IP address, alphanumeric IDs, type of device, operating system and browser type, information regarding the volume and status of data transmission, click-through statistics, the name of the domain and host from which you access the Internet, the date and time you accesses portions of our Game, for system administration and statistical purposes.  This is statistical data about our users’ browsing actions and patterns, and we do not use them to identify any individual, except if required by the law.
  1. ACCESS TO INFORMATION AND UPDATING, VERIFYING AND DELETING PERSONAL DATA
  1. At any time, you can make a written request to have access to all the personal information that we hold about you.  
  2. If you choose to delete your account, you may contact us by email at [email protected] and request that your account be deleted.  
  1. CHANGES TO OUR PRIVACY POLICY
  1. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.  You should visit this page periodically to review any changes to the Privacy Policy.
  1. USER FEEDBACK AND COMPLAINTS
  1. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to us by email at [email protected]