PUBLISHED ON JULY 6, 2018
At EUGEN SYSTEMS, we collect personal data to support our products and services, while respecting all applicable laws, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA), and regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, “General Data Protection Regulation”, or “GDPR”). As defined in the GDPR, “personal data” means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Table of contents:
- When does EUGEN SYSTEMS collect your personal information?
- What personal information does EUGEN SYSTEMS collect?
- How does EUGEN SYSTEMS use my personal data?
- For how long does EUGEN SYSTEMS keep my personal data?
- With whom does EUGEN SYSTEMS share my personal data?
- Does EUGEN SYSTEMS make my personal information public? Who can see my personal information?
- What are my rights?
1. WHEN DOES EUGEN SYSTEMS COLLECT YOUR PERSONAL INFORMATION?
EUGEN SYSTEMS collects and processes your personal information at different times when you interact with our Services. Generally, personal information is collected when:
(a) you use a Service,
(b) you create an Account,
(c) you make a purchase within our Services,
(d) you create user generated content,
(e) you watch advertisements within our Services,
(f) you sign up for a newsletter,
(g) you contact EUGEN SYSTEMS customer service and during technical support sessions,
(h) you chat with other users of the Services,
(i) you participate in a beta or otherwise download a patch or a demo, or
(j) you share or otherwise contribute to our social media channels or other community websites.
Whatever the activity may be, we will only collect personal information to the extent necessary to provide you with the Services and fulfil your requests.
2. WHAT PERSONAL INFORMATION DOES EUGEN SYSTEMS COLLECT?
2.1 When you use EUGEN SYSTEMS services
2.1.1 While Browsing EUGEN SYSTEMS websites
IP addresses. EUGEN SYSTEMS also collects Internet Protocol (IP) addresses for safety and security reasons. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
Other passively collected information. While browsing our sites, EUGEN SYSTEMS may, on its own, or with the help of third party tools, collect non-personally identifiable information concerning your gaming hardware, habits, behaviors and use of our Services. EUGEN SYSTEMS collects such information to better adapt our Services to users’ interests, and for a better quality of our Services. The information collected may contain the following, without limitation: device unique identity, including MAC address, console, mobile, tablet and console unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.
2.1.2 Registering on a EUGEN SYSTEMS service
To access certain Services, you will need a EUGEN SYSTEMS Account (“EugNet account”). During the creation of your Account, we will ask you to provide your user name, password, email address, date of birth (or age) and country of origin. This information is mandatory to create an Account. On other Services, EUGEN SYSTEMS may ask you additional personal information relevant to the Service such as your phone number, home address, or geo-location information.
2.1.3 Creating a EUGEN SYSTEMS account
By creating a EUGEN SYSTEMS Account, you agree to receive newsletter or adverts about EUGEN SYSTEMS products, services, and sales. You can unsubscribe at any time by:
(a) clicking the unsubscribe link contained in all EUGEN SYSTEMS email marketing messages
(b) contacting on email@example.com with your unsubscribe request
(c) sending your unsubscribe request to EUGEN SYSTEMS, Attn: Privacy Rights Administrator c/o Legal Department, 151 rue Saint Denis, 75002, Paris, France.
To access certain Services, you will need to give an additional consent to allow EUGEN SYSTEMS to share some of your personal data with third parties, such as companies or organizations, which provide services and products you may be interested in. In this case, you can unsubscribe from third parties’ communications through the mechanisms provided by the third party.
2.1.4 Contacting EUGEN SYSTEMS
2.1.5 Participating to contests and sweepstakes
EUGEN SYSTEMS may offer you the opportunity to participate in online surveys, questionnaires, contests and sweepstakes. To participate, you may need to provide your first name, your family name, e-mail address, date of birth, your address and country of residence. If you choose to participate in contests, sweepstakes, surveys and questionnaires, your personal data may be processed to allow you to participate, and for internal statistical use.
2.1.6 Interacting on forums
Whenever you participate or interact with other users on a forum, EUGEN SYSTEMS collects the content of your communications, the time and the location of your activities, as well as your online ID and your IP address.
2.1.7 Social media and other third parties’ platforms
2.2 Whenever you play EUGEN SYSTEMS games
2.2.1 Registering when activating a EUGEN SYSTEMS game
If you play EUGEN SYSTEMS games on a third-party console, your ID for this console will be disclosed to EUGEN SYSTEMS, in order to let EUGEN SYSTEMS create your EUGEN SYSTEMS Account. You must have a EUGEN SYSTEMS Account in order to access certain online features. From your console, EUGEN SYSTEMS receives your username and your password, your e-mail address, your date of birth, and your country of residence.
2.2.2 Creation of user generated content
Some Services give you access to tools in order to allow you to create and/or share unique content. This User-Generated Content may be collected by EUGEN SYSTEMS; this content may also contain your personal information or the personal information of others (for instance, your name, or a picture of you). Please exercise caution: EUGEN SYSTEMS is not liable for any negative consequences linked to your disclosure of User-generated content.
2.2.3 In-game data collection
3. HOW DOES EUGEN SYSTEMS USE MY PERSONAL DATA?
3.1 Legal basis for your personal data collection and processing
EUGEN SYSTEMS processes your personal data, wherever necessary:
- To provide you with the Services (creation of your EUGEN SYSTEMS account, bug detection, fighting fraud, online payment, etc.)
- To offer the best possible experience to users, and improve the Services (in-game data analytics, etc). It is in EUGEN SYSTEMS’s legitimate interest to process your data for these purposes.
- To provide you with supplementary services (custom content, etc.). In such case, EUGEN SYSTEMS will ask for your consent before processing your personal data for this purpose.
DESPITE OUR REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA. OUR PRIVACY POLICIES AND PROCEDURES ARE “AS IS” AND EUGEN SYSTEMS MAKES NO REPRESENTATIONS AS TO THE FITNESS FOR A PARTICULAR PURPOSE OR MERCHANTABILITY.
4. FOR HOW LONG DOES EUGEN SYSTEMS KEEP MY PERSONAL DATA ?
5. WITH WHOM DOES EUGEN SYSTEMS SHARE MY PERSONAL INFORMATION?
EUGEN SYSTEMS does not disclose your personal data to any third party without your prior consent.
5.1 Sharing your personal data with third parties
5.2 Sharing your personal data with government authorities
In accordance with relevant laws, EUGEN SYSTEMS may have to disclose your personal data to a judiciary or administrative entity, whenever such disclosure is deemed necessary for protecting, challenging or enforcing the legal rights of EUGEN SYSTEMS, its Users, or third parties. Unless required by law, EUGEN SYSTEMS will not be required to notify you of any such disclosure.
5.3 Business Information
For practical reasons, we treat Personal Information submitted to us in a business capacity different from information we receive in a non-business capacity. Personal Information submitted to us in a business capacity (e.g. resumes) may be shared with third parties as described at the time of collection.
6. DOES EUGEN SYSTEMS MAKE MY PERSONAL INFORMATION PUBLIC? WHO CAN SEE MY PERSONAL INFORMATION?
EUGEN SYSTEMS Services may offer a public profile feature (“Public Profile”) that allows you to publish information, including personal information, to the public Internet. Other than as stated on the applicable Public Profile site, the information you upload or input to your Public Profile will default to the privacy level you choose at sign-in, and you can choose to change the privacy settings at any time. By default, certain aspects of the Public Profile are set to “public”. Those aspects of the Public Profile that are designated as “public” will be visible to everyone, potentially including people not registered within the EUGEN SYSTEMS environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your personal information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent.
Unless stated specifically to the contrary in a given Service, our Services are not intended for children, and EUGEN SYSTEMS will not request any Personal Information from children. For games that are not directed at children but nonetheless likely to appeal to younger players, we take additional steps to limit access to these Services on age grounds, and limit data collection for underage players to only what is necessary to support the internal operations of the Service.
In certain jurisdictions, for we may allow a child to register for specific Services with parental approval. In these circumstances, we will take additional steps to protect the child’s privacy, by notifying the parent about our information practices with regard to children, and asking for consent before processing their child’s personal information. Parents may delete their child’s account, change their child’s privacy settings, or access and modify their child’s personal data at any time by contacting customer support at https://www.eugensystems.com/contact-our-support/.
In all cases, use of the Services by Children must take place under the responsibility of their parents or legal guardians and any use of the Services is assumed to have been validated by them. AS FAR AS IS PERMITTED BY APPLICABLE LEGISLATION, EUGEN SYSTEMS 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.
8. WHAT ARE MY RIGHTS?
You have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by EUGEN SYSTEMS, as well as the right of data portability. You can exercise these rights or terminate your EUGEN SYSTEMS account by writing to EUGEN SYSTEMS customer support, via the following address : firstname.lastname@example.org. EUGEN SYSTEMS will answer your request within a month following the receipt of your demand. EUGEN SYSTEMS reserves the right to extend this delay up to three months if it necessary regarding the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand. For any data processing activity requiring your consent (cookies, behavioral advertising…etc), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing. You may also address any complaint to the national supervisory authority of your country.
Do not Track: EUGEN SYSTEMS does not currently respond to Do Not Track (DNT) settings in your browser.
You can also write us at the address below:
EUGEN SYSTEMS. Attn: Privacy Rights Administrator c/o Legal Department
151 rue Saint Denis, 75002, Paris, France.
Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.