EUGEN SYSTEMS PRIVACY POLICY

PUBLISHED ON JULY 6, 2018

PLEASE READ THIS PRIVACY POLICY CAREFULLY

Welcome to EUGEN SYSTEMS, a French video game company. This Privacy Policy explains our privacy commitment to our players and users of our Services (hereinafter “Users”). This Privacy Policy is incorporated as part of the EUGEN SYSTEMS Terms of Use, accessible at https://eugensystems.com

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.

By using EUGEN SYSTEMS’s services, you authorize EUGEN SYSTEMS SA to process your personal data according to this Privacy Policy. If you do not accept the terms of this Privacy Policy, please refrain from using our online games or our games’ online functionalities, our websites, our mobile apps and any other online EUGEN SYSTEMS products and services (hereinafter “Services”).

In accordance with this Privacy Policy, the Data controller is EUGEN SYSTEMS SA, with its headquarters at 151 rue Saint Denis, 75002, Paris, France.

Table of contents:

1. When does EUGEN SYSTEMS collect your personal information?
2. What personal information does EUGEN SYSTEMS collect?
3. How does EUGEN SYSTEMS use my personal data?
4. For how long does EUGEN SYSTEMS keep my personal data?
5. With whom does EUGEN SYSTEMS share my personal data?
6. Does EUGEN SYSTEMS make my personal information public? Who can see my personal information?
7. Minors
8. What are my rights?
9. Privacy Policy changes
10. Contacts

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

Cookies. EUGEN SYSTEMS uses cookies on the Services. A “cookie” is a small bit of record-keeping information that web sites often store on a user’s computer. Cookies are not intended to include people’s names, or other information that is directly identifiable; rather, they are typically used to quickly identify a user’s device and to “remember” things about the user’s visit. EUGEN SYSTEMS may set cookies for your web browser as you visit our websites, use our products, or visit a website where EUGEN SYSTEMS provides ads, content or analytics. For example, EUGEN SYSTEMS uses cookies to keep track of selected items in your shopping cart on our online store, and to remember your Account identifier. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to shop online or to access certain features of our Services. Each browser is different, so check the “Help” resources for your web browser to learn how to change your cookie preferences. In addition to EUGEN SYSTEMS using cookies on our network of websites, EUGEN SYSTEMS may allow certain partners to set and access their cookies on your computer. These companies’ use of cookies is subject to their own privacy policies, not the EUGEN SYSTEMS Privacy Policy. Please review them carefully. For more information about cookies, please see http://www.allaboutcookies.org.

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 eugsupport@eugensystems.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

EUGEN SYSTEMS may ask for your first name, family name, e-mail address and your date of birth to answer your demands to the EUGEN SYSTEMS Customer Support, to confirm any information or transaction on your EUGEN SYSTEMS account, and to give you information regarding the Services (for instance, if you lose your password or if we make changes to the Terms of Use).

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

EUGEN SYSTEMS may also collect personal information on third party social networks, platforms or services. By playing a EUGEN SYSTEMS game through a social network or other third party platform, or by connecting to such a third party network, platform or service via one of our products and/or Services, you authorize EUGEN SYSTEMS to (1) collect, store, and use, in accordance with this Privacy Policy, any and all personal information that you agreed the social network or third party platform could provide to EUGEN SYSTEMS based on your settings on the social network or platform, and (2) share any and all of your personal information with the social network or other third party platform, through the social network/third party platform’s Application Programming Interface (API). You agree to this sharing when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) one of our applications through a social network, or other third party platform or service.

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

Whenever you use the Services, EUGEN SYSTEMS may collect, store and process your in-game data, including but not limited to: your game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information. EUGEN SYSTEMS will use this information to improve the Services, to personalize them to your interests, and otherwise upgrade your gaming experience. Any information collected by EUGEN SYSTEMS in accordance with Article 1 of this Privacy Policy may also be used in an aggregated form to identify specific patterns regarding the use of our Services.

3. HOW DOES EUGEN SYSTEMS USE MY PERSONAL DATA?

The information you submit to our Services is collected and used by EUGEN SYSTEMS as set out in this Privacy Policy. In addition, EUGEN SYSTEMS may use the submitted information to answer your demands, to send your order confirmations and other information regarding your EUGEN SYSTEMS Account, to send you advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on your preferences. We also use your personal information for our internal marketing and demographic studies, so we can constantly improve the Services we provide you and to better meet your needs.

EUGEN SYSTEMS may have to duplicate some of your personal data within its databases for technical reasons, or for any other reason indicated in this Privacy Policy. EUGEN SYSTEMS may use your IP address and Console ID to enforce the EUGEN SYSTEMS Terms of Use. In case of misuse of the Services by any User, EUGEN SYSTEMS reserves the right to block such User’s EUGEN SYSTEMS Account, IP address or console ID, as provided by licensed console manufacturers. EUGEN SYSTEMS may use your date of birth or your age to control access to its forums and live chats, in accordance with the relevant laws. EUGEN SYSTEMS does not monitor all chat communications on its services. However, EUGEN SYSTEMS reserves the right, at its sole discretion and without notice, to modify or delete any communications on its service. EUGEN SYSTEMS may use all data collected in the forums and chat logs to enforce its Terms, to carry out its legal obligations, and to protect its rights and the rights and safety of its affiliated companies, users, and employees. Your information may be disclosed to any relevant judiciary or administrative entity, in accordance with the relevant legal provisions.

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.

3.2 Security

We take your privacy and the security of your personal information very seriously. To protect your personal information, EUGEN SYSTEMS maintains appropriate safeguards to ensure the security, integrity and privacy of the information you have provided. We use robust security measures to protect personal information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. In addition, we take reasonable steps to assure that third parties who collect personal information on our behalf provide sufficient protection of personal information, in addition to requiring their compliance with this Privacy Policy at all times. Please note, we will notify Users of a data breach pursuant to applicable law.

However, please note that no existing data transmission method on the web, or electronic storage, can guarantee the absolute security of your personal data. If your EUGEN SYSTEMS accounts and personal data are protected by a password, you are responsible for ensuring this password’s confidentiality. Please do not disclose this password. If you share a computer with other people, please consider disconnecting from your accounts before allowing others to use your computer. Services may contain links leading to third party websites, such as but not limited to social media sites. Whenever you click on a link leading to a third party’s website, you agree to leave EUGEN SYSTEMS Services as governed by this Privacy Policy, and you understand and agree that EUGEN SYSTEMS does not control such third party’s website. EUGEN SYSTEMS cannot guarantee that third parties’ websites will be governed by the same security and confidentiality obligations. EUGEN SYSTEMS is not liable for the use of your personal data by these third parties. Please consider checking privacy policies of any service provider you transfer your personal data to.
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 ?

Unless relevant legal provisions mandate a different data retention period, EUGEN SYSTEMS will store your personal data only as long as necessary to process it according to this Privacy Policy. For instance, we may retain certain information after you close your account for a period of time needed to protect EUGEN SYSTEMS from legal claims. In this case, we will archive your personal data during the relevant statutory period of limitations.

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

While browsing on EUGEN SYSTEMS website, or while using EUGEN SYSTEMS Services, external providers may collect your personal data for and on behalf of EUGEN SYSTEMS, and EUGEN SYSTEMS may share some of your personal data with these partners to allow the functioning of the Services. For example, these third parties may help deliver your purchases, provide discounts or offer products, promote the Services, perform electronic payment processing, and any other service that may be required by EUGEN SYSTEMS. External providers must comply with this Privacy Policy when collecting your personal data. These external providers will share your personal data with no one other than EUGEN SYSTEMS, and they may not use your data for their own independent marketing purposes, unless you consent to their privacy policy and terms directly.

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.
We are not responsible for disclosure by other users of your Personal Information, including without limitation, videos, images or photos that you choose to make public on the EUGEN SYSTEMS Services. Also, please remember that the Personal Information you provide to us as part of your Public Profile may reveal or allow others to identify aspects of your life that you may not choose to state on your Public Profile directly (for example, your picture may reveal your gender). Certain Services may feature a friend finder tool. By using our friend finder tools, you acknowledge that these tools will help you find your contacts, and will also allow your contacts to associate your EUGEN SYSTEMS Account, other EUGEN SYSTEMS accounts (if any), and related gaming entitlements, including games played on PC, mobile and console platforms with your social networking profile and/or email address. Your resulting friends’ list, which may be accessible across EUGEN SYSTEMS’s sites, will be subject to this Privacy Policy. Note that the friends that you choose to include on your friend list may be able to find and/or identify you in the context of different EUGEN SYSTEMS products and Services, and may see the profiles and information you have made visible to them or to everyone. Similarly, EUGEN SYSTEMS may also collect or receive information about you from other EUGEN SYSTEMS users who choose to upload their emails and other contacts. This information will be stored by us and used primarily to help you and your friends connect.

7. MINORS

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://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 : eugsupport@eugensystems.com. 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.

9. PRIVACY POLICY CHANGES

EUGEN SYSTEMS reserves the right to modify this Privacy Policy at any time. As a result, please consider checking this Privacy Policy from time to time. Your use of the Services after EUGEN SYSTEMS changed this Privacy Policy shall signify that you agree with these changes. If you do not accept changes made to this Privacy Policy, please refrain from using the Services.

10. CONTACTS

For any question related to your personal data processing and this Privacy Policy, please contact EUGEN SYSTEMS at the following address: eugsupport@eugensystems.com.

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.