INTRODUCTION

We recognize that persons who access and/or use (“you” or “Users”) our games, whether played on our website, on mobile devices, PCs or on other platforms, (“STEPICO GAMES”, “we”, “us”, “our”) and other related services, including but not limited to customer supporting, marketing and advertising, (collectively, the “Services”) value their privacy. 

We respect the privacy rights of our users and are committed to protecting the information collected through our games, this website, any products, mobile applications, console or PC applications (collectively “Services”). By using the Services, you are consenting to this Privacy Policy and the processing of your data in the manner provided in this Privacy Policy.

The Stepico Games company may store some data about you. You have the right to know what data we store, update this data, or request its deletion.

This Privacy Policy provides important information regarding:

  1. a) the data collected from you and the ways we collect your data,
  2. b) the reasons why we collect your data,
  3. c) to whom we disclose your data, and
  4. d) the options you have about your personal data.

Unless stated otherwise, this Privacy Policy applies to the Services and all data that we collect from you. We therefore provide this Privacy Policy to help you make an informed choice about whether to use or continue using our Services. 

We reserve the right to make changes to this Privacy Policy in order to reflect any changes in data protection laws or our internal policies. We will endeavour to notify you of such changes but, in accepting these terms, you hereby undertake to regularly check for an updated version of this document at: http://heroring.app/privacy/ for as long as you use the Services.

STEPICO GAMES is the controller responsible for your personal data processed under this Privacy Policy.

WHAT INFORMATION DO WE COLLECT?

STEPICO GAMES’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service. When you install any of the STEPICO GAMES games or applications, we may collect and record the information you provide us voluntarily through the social networking website you use to access the Service (“SN Website”) in accordance with the policies and terms of the SN Website.

When you use the Services, we may collect the following data:

  1. Data provided by you

To use the Services, you may directly provide certain personally identifiable information to us, such as:

  • Contact information (e.g. your name, e-mail address, telephone numbers)
  • Registered user name and password
  • Character Information (e.g. Account ID, character name, profile picture. Please be reminded that such information may be disclosed to other users in connection with the use of the Services and may also be made available to your connections or the public on third party services)
  • Personal content preferences
  • Profile information (e.g. profile photo)
  • Messages to the Services (e.g. chat logs, your support tickets)
  • Billing and financial information (Please be reminded that the use of any merchant service provider and/or third party platforms for the payment of the Admission Fee is subject to the privacy policy of the relevant merchant service providers and/or third party platforms)
  • Other data that you voluntarily provide (e.g. data to identify a lost account)
  1. Data collected automatically

When you access our Website or use the Services, we may use cookies  and/or other similar technologies. Cookies are small text files stored by browser(s) on your desktop computer or mobile device. Most web browsers automatically accept cookies, but you can usually modify browser setting to decline cookies. If you choose to decline cookies, you may not be able to access certain Services and may experience technical problems receiving current information from the cookie-disabled services. The use of cookies and/or other similar technologies is to identify your browsers and to collect data from your device such as:

  • Data about your Account
  • Internet Protocol (IP) address, web request, domain name, URLs, referring/exit pages, platform type and mobile device identifiers (e.g. your device ID, advertising ID, MAC address, IMEI)
  • Data about your device (e.g. device name, operating system, browser type and language)
  • Data we collect with cookies and similar technologies
  • Monitoring of aggregate metrics (e.g. total number of visitors, pages viewed, usage of the Services)
  • General location data
  • Precise geo-location data (i.e. GPS)
  • Data about your use of the Services (e.g. number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, your game play and activity, your game progress, your interactions with other players inside the Services)
  • Other pieces of information in connection with your various activities within or through the Services or otherwise that are sent by your browser, device or computer system when you access the Services, which are automatically tracked and recorded by our servers
  1. Data collected from our partners

When you access the Services through any third party services such as social networking sites (e.g. Facebook, WeChat, Google) or from any mobile devices, you allow us access to certain information stored on these third party services or mobile devices such as:

  • Demographic data (e.g. determination of your IP address)
  • Data to fight against fraud (e.g. refund abuse in games or click fraud in advertising)
  • Data from platforms that the games run on (e.g. verification of  payment)
  • Data associated with your device (e.g. device type, technological information, telephone number, country, contacts)
  • Data to do advertising, marketing and analysis

 In case you use our forums, we may additionally process data generated automatically your activity in the forum: date of last activity, subscribed threads, favorite posts, achievements in the forum, redpoints (points on the forum), private messages and posts.

We don`t collect any credit card and/or billing information when you purchase products or services (such as digital content) online. However, you may be required to provide credit card and/or billing information to one of our third-party vendors in order to complete a purchase.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW DATA ABOUT YOU IS COLLECTED?

We may collect and process your personal and non-personal information, both individually and combined together, in the following ways:

  1. data you give us via Services;
  2. data given when you contact us or report a problem with Services;
  3. data about your activity as a user of the Services (in addition to your IP address, country of origin, purchases, account of in-game virtual goods and currencies) – is collected automatically;
  4. data provided by third parties such as our affiliates, Social Media, our vendors (for example merchandise vendors) or partners (for example, advertisers, media partners or platform providers).

We may also create or collect device-identifiable information (DII), such as cookies, unique device and advertising identifiers, statistical identifiers, usernames, and similar identifiers that are linkable to a browser or device.

HOW WE USE PERSONAL DATA?

We use the information we collect from our Services to provide, maintain, protect and improve our Services, to develop new Services and offerings, and to protect us and our users.

Generally, we may use the personal data we collect from you for the purposes and lawful bases described below:

Use of information based on your consent. We may use personal data about you based on your express consent, for example to send you marketing communications, surveys, news, updates and other communications. Users may be able to withdraw their consent at any time in accordance with applicable laws.

For our legitimate interests. The personal data may be used to improve and develop our products and services; analyse the use of our Services and generate aggregate statistics about our User community; personalize your experiences (e.g., for your geographic area); send or display targeted marketing; facilitate software updates; assist in security and fraud prevention; for system integrity (preventing hacking, cheats, spamming, etc.); facilitate our business operations and maintain appropriate business records; operate company policies and procedures; facilitate our response to legal process (e.g., a court order, warrant or subpoena); enable us to merge, sell, acquire, or transfer assets; and for other legitimate business purposes permitted by applicable law. 

HOW WE HANDLE YOUR INFORMATION?

Where do we store it? The data we collect from you is stored on our secure servers in Europe. We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction or damage. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

How long are we going to store your data? We will retain your personal data only for as long as needed in order to fulfill the purposes outlined in this Privacy Policy. In certain special cases, a longer retention period might be required by law, such as for tax reasons, accounting purposes or other legal requirements and obligations. When we will no longer require your personal information in order to provide our game related services to you, we will either delete it or anonymize it.

We review our retention periods on a regular basis.

International transfers. Your data may be processed, stored and transferred to countries outside your country of residence and beyond the European Economic Area (EEA), such as Switzerland or the United States. Privacy laws in these countries may not offer the same level of protection as in your country or in the EEA. But whenever we share your personal data outside the EEA, we will do so on the basis of EU standard contractual clauses or the Privacy Shield Framework, which are lawful measures to transfer your data and establish adequate protection of your personal data.  [By accepting this Privacy Policy, Users understand and agree that your data may be collected, stored, used in any country and/or transferred to any country in the world. Because different countries may have different data protection laws than Users’ own country, we will try to ensure that adequate safeguards are in place to protect Users’ data.]

WHO MIGHT WE SHARE YOUR INFORMATION WITH?

Vendors and Partners

Vendors and partners provide goods and services (for example, platform providers, media partners, event ticket providers, merchandise vendors, survey providers, billing, consumer services support, consultancy, information technology hardware and software) to Activision in order to support, operate and develop the Properties and to deliver marketing communications on our behalf. Vendors use your Information to execute, deliver and/or from time to time improve the services they provide. We do not share Information with vendors to use for their own direct marketing purposes or any other purpose other than those set out in this section without your consent

Law

We will disclose your Information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability.

Sale of Our Business or Assets

Separately, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Activision’s customer information including Information and communications may be transferred to our successor or assign.

Links to Third party sites

The Service may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We strongly recommend that you carefully read the privacy policy of any website you visit

COOKIES

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, gaming performance and use of the Services. Our system may not respond to Do Not Track requests or headers from some or all browsers.

Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Our cookies are typically used to quickly identify a user’s computer, browser, or device and to “remember” things about prior visits (such as the user’s use of various features on the service). It is possible to switch off cookies by setting your browser preferences.Turning cookies off may result in a loss of functionality when using our website.

Flash Cookies: We may also use flash cookies, also known as “shared objects,” on our sites that employ Flash technology. Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site. You can clear Flash cookies already on your device by setting the Flash local storage setting to zero

Web Beacons: A “web beacon” is an electronic image that allows websites to count users who have visited certain pages or viewed certain advertisements.

Internet Log Files: We may also keep track of IP addresses used to access the Services for various reasons. An IP address is a number that is used by a networked device and will identify your point of connection to the internet. Depending on your network configuration, it may also identify your computer, or other device. A MAC address or other device ID identifies one specific piece of hardware.

Analytic Metrics Tools and Other Technologies: Other information that may be passively collected by us includes log files that record information about your hardware, product use, service use, or website use, including website navigation and game telemetry activity. We also use these log file entries for our internal marketing, service design, technical support, and demographic studies, so we can constantly improve the Services we provide you.

Advertising Service Providers: Some of the Services are supported by advertising provided by us or various third-party advertising agents, such as ad networks, data exchanges, traffic management service providers and marketing analytics service providers. The information such Advertising Service Providers may collect, or we may share with them, includes your device type, IP address, other device ID, browser type, language, operating system and generalized geographic location, content and ads you, or others who are using your device, visited or viewed and the frequency of your visit/viewing; and information regarding your use of or activities in connection with the Service (e.g., time spent using a mobile application or your purchases).

Third-party Advertisers: The Company works with various third-party advertising agents that use cookies, web beacons, and similar technologies to collect information. We do not have access to or control of the third-party tracking technologies, and we encourage you to review their privacy policies before disclosing information to such parties.

 

CHILDREN

We respect the privacy of children and encourage parents and guardians to take an active role in managing their children’s online activities. If you are under 16, please make sure you have consent from you parent and/or guardian before using the Services. Some of our Services are not available for use for children under 16 years old, and we do not knowingly collect personal information from children in connection with those Services.

HOW CAN I ACCESS THE INFORMATION YOU HOLD ABOUT ME?

You may review, update, correct or delete any personal information by changing the applicable information by changing the applicable information through the SN Website. If you completely delete all this information, your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we are not legally obligated to retain the record.

You have the right to object to the processing of your personal data in certain situations and for marketing purposes at any time. You can do so by contacting us on the email address: 

support@stepico.com

You may object to the processing of your personal information based on a legitimate interest on grounds relating to your particular situation. You may, in particular, control the extent to which we market to you and you have the right to request that we stop sending you marketing messages at any time. 

In certain circumstances, you can request that we transfer personal information that you have provided to us. You can send your request to us here.

Where we rely on your consent in order to process your personal information, you have the right to withdraw such consent to further use of your personal information at any time. 

For each of the rights described above, you can also send your request to us by using the contact details set out above.

We hope that we can satisfy queries you may have about the way we process your personal information. However, if you have unresolved concerns you also have the right to complain to data protection authorities. You can bring the complaint in your member state of residence, place of work or where an alleged infringement of data protection law occurred.

In case of any concerns or questions about your privacy, please do contact us and we will do our best to assist you. You can reach us at: support@stepico.com or regular mail at: __________.