Privacy Policy – Version 1.2, May 25, 2018

Last Updated: 25.05.2018
Effective Date: 25.05.2018

EverdreamSoft SA (“EDS”)
Rue de la Muse 2
1205 Geneva
+41 22 321 72 10
EverdreamSoft SA

Your privacy is important to us, and we take our responsibility of caring for it seriously. This policy describes what information EDS collects when you use the mobile, online and downloadable products and services ("products") offered by EDS. By using our products, you consent to this policy.

Due to the nature of our close cooperation with European Games Group AG, Oberanger 43, 80331 Munich, Germany (“EGG”), as game publisher, please consider all your information in the game Spells of Genesis to be shared with EGG. Please review EGG’s Privacy Policy at http://gamesgroup.eu/data-protection/ and their sub-processors. By using our product, you consent to EGG’s policy as well.

However, EDS is operating other products or services which may also gather some data:

TABLE OF CONTENTS

Information We Collect
How We Collect Information
How We Use Your Information
Information We Share with Third Parties
Where We Hold Your Information
How We Protect Your Personal Information
Duration of Storage, storage periods
Your Choices and Controls
Third Party Services
Job Applications
Changes to Our Policy
Contact Us

Information We Collect

The information we collect depends on what products you use and how you use them. The controller of the personal information collected is Mr Nicolas Sierro, Rue de la Muse 2, 1205 Geneva, +41 22 321 72 10, email: Nicolas Sierro (“EDS”).

A. Information You Give Us Directly

We collect information you provide us, including for example:

When you participate in social features (such as chat or comment in social media), the information that you disclose is public information. We may store and access it, and it may be read, copied, collected or used by other users without your consent. Please make sure your privacy settings within these external services reflect your preferences.

When you participate in online multiplayer games your in-game profile information, gameplay, and statistics are visible to all. We may record your gameplay, including your controller button inputs, and replay these together with your profile information and game statistics to other players in-game without further notice to you, for example as part of a spectator mode, or for out-of-game promotional purposes.

B. Other Information We Collect When You Use Our Products

We collect other information automatically when you use our products, including:

We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.

C. Information Provided to Us by Third Parties

If you play or purchase our product on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.

D. Other Third Parties

We may also receive information from third parties, like Facebook or Game Center, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us.

We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found on Appendix. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.

How We Collect Information

We collect some information from you when you provide it to us directly, such as via an online form or when you talk with our customer support team. We and third parties also use certain technologies described below to collect information to deliver excellent experiences.

A. Cookies and Similar Technologies

Cookies are small text files stored on your Internet browser. We use cookies and similar technologies to help us understand things like what web pages, features or ads you view and what games you play. This information helps us keep track of your shopping cart, measure the effectiveness of our advertising, make sure you don't see the same ad repeatedly and otherwise help enhance your user experience. You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to http://www.allaboutcookies.org or the guidance provided by your individual web browser if you'd like help in managing your cookie preferences.

We use also other technologies for similar purposes as a cookie. We use pixels or clear GIFs to collect information about your use of our products and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our products, troubleshoot technical problems, detect and prevent fraud and enforce our User Agreement. Other examples include HTML 5 cookies, Silverlight Application Storage, and device fingerprints. We currently do not respond to Do Not Track (DNT) signals. We may adopt a DNT standard if one is established. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.

We also use Analytics, Advertising, Anti-Cheat and Anti-Fraud technologies in our products that utilize the same cookies and similar mechanisms. These technologies are described below.

B. Analytics Technologies

We use our own servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.

For instance, EDS may collect and store data from your computer or device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), information about your feature usage, gameplay and usage statistics, system interactions and peripheral hardware for purposes described in section 3, below. If you play a game offline, this data will be stored on your device and transmitted to EDS when your device connects to the Internet. If you participate in online services, EDS also may collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.

Third party analytics services integrated into our products may combine the information they collect in connection with EDS' services with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. A representative list of third party analytics companies that operate in our products can be found at Appendix.

C. Advertising Serving Technologies

Some of our products employ advertising serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different websites, mobile apps and devices. The ads can be tailored to your interests. For instance, you may be presented with an offer for a game we think you might enjoy. Or if you express interest in a game, you might receive an advertisement later for that game or similar products from EDS or third party sites. Other in-game advertising technologies enable advertising to be temporarily uploaded to your game, web browser, or mobile device and later replaced while you are online.

These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes:

Third party advertising companies may combine the information collected in the context of delivering an ad to you via our Products and Services with other information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. A representative list of advertising serving companies that operate their own networks on our sites and online and/or mobile products and/or services as well as how to opt out to the extent applicable can be found at Appendix.

To learn more about some of these ad networks' practices, or to opt out of third party targeted advertising, you can visit https://www.networkadvertising.org, https://www.aboutads.info/choices/, http://youradchoices.ca/, or https://www.youronlinechoices.eu. Note that opting out does not mean you won't see ads; it just means that the advertising you see may be less relevant to your interests.

D. Anti-Cheat and Fraud Prevention Technologies

EDS strives to provide a safe and fair gaming environment for all players. When you log in to one of our products, set up an EDS Account or make purchases, we or third parties may use cookies and similar technologies, or collect data about your machine or device, to create a machine "fingerprint" or "hash" of your machine components, for fraud prevention, security and authentication purposes. We also may use other anti-cheat or fraud prevention technology with our products

How We Use Your Information

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

To operate our business and to enhance and personalize your game experience including to:

To provide you support, including to:

The legal basis for the processing of data is Art. 6 para. 1 sent. 1 lit. f of the GDPR. Our justified interest results from the mentioned purposes for data collection.

Information We Share with Third Parties

We do not share personal information that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.

We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys, facilitating credit card processing payment, debt collection agency, or sending emails. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.

We do not knowingly disclose personal information about children under 18 years of age to independent third parties even with consent.

However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.

We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our games. An example is the Facebook "Like" button.

Where We Hold Your Information

Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in Switzerland or any other country in which EDS, its subsidiaries, or third party agents operate. By using our products, you consent that your personal information may be transferred to recipients in Switzerland and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

How We Protect Your Personal Information

Security of our players' information is a priority at EDS, and we take a range of measures to help protect it. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control. We process the information collected from you according to the European data protection law. All employees are obliged and have been advised to maintain data confidentiality and privacy obligations, and that received.

Duration of Storage, storage periods

We store your data only as long as this is necessary for the provision of our online offer and the associated services or we have a legitimate interest in the further storage. In all other cases, we will delete your personal information except for such information as we may need to maintain in order to fulfill contractual or statutory (e.g. tax or commercial) retention periods (e.g. invoices). Contractual retention periods may also arise from contracts with third parties (e.g. owners of copyrights and ancillary copyrights). Data that is subject to a retention period are saved until the expiration of the deadline.

Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of information. For example, you can update your account information and preferences, choose to opt in or out of EDS marketing emails and choose whether to share your information with select EDS partners. If you would like to opt out at any time after granting approval, use the provided controls within the product or contact us directly.

You may deactivate your EDS Account or delete the personal information associated with your account by using the provided controls within the product or by contacting us directly. If you do so, you will no longer have access to the EDS games or services associated with your account. Note that EDS may retain information needed to resolve disputes, enforce our user agreements, protect our legal and tax rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you services, create and improve our products, comply with the law, and to run our business.

You can access the personal information we hold about you. To request access, contact us directly. Before we process any request, we may ask you for certain personal information in order to verify your identity and we may request payment where allowed by law. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond to your requests in a reasonable timeframe.

You have additionally, under certain conditions, the right to rectify, erase or restrict the processing of your personal data or have the right to object the processing. You also have the right for data portability. You can also object at any time to the processing of your personal data for advertising purposes ("advertising conflict"). Please take into account that for organizational reasons there may be an overlap between your revocation and the use of your data as part of an ongoing campaign. If you have given us consent to the processing of your data, you can withdraw them at any time with effect for the future. The lawfulness of the processing of your data until the revocation remains unaffected.

You can file a complaint with a data protection authority. You can contact the data protection authority, which is responsible for your place of residence or your state, or the data protection authority which is responsible for us. E.g for Germany, this is: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 27, D-91522 Ansbach, Germany, poststelle@lda.bayern.de.

You may also contact the Federal Data Protection and Information Commissioner in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home.html

You also may adjust your browser settings to block certain online tracking, such as cookies.

Third Party Services

Our websites and products may contain advertising or third party services (such as the Facebook Like button or links to third-party websites). If you click on those links, including an advertisement, you will leave EDS website and go to the site you selected. If you visit a third party website or use a third party service, you should consult that site's or service's privacy policy. EDS does not verify the data protection conditions of third parties.

Job application

This Privacy Policy sets out how EDS uses data from candidates that apply for or that EDS considers for a position at EDS. Candidates may interacting with EDS human resources department verbally or in writing (“Application”).

Personal data which you submit on registration when applying for a particular position at EDS, such as your name, e-mail address, date of birth, telephone number, IP address, device ID, curriculum vitae, photograph, references and certificates or other information from which your identity is discernible.

Information we collect from third party public sources, such as LinkedIn or Xing or other career networking services.

By applying, you explicitly confirm that you are interested in an employment at EDS. You therefore voluntarily provide your personal data to be used for recruiting purposes, in particular for filing and matching your profile with any and all open positions at EDS, including beyond those for which you specifically applied.

If there is a job opportunity at EDS which matches your profile, EDS may forward your data to the responsible EDS managers in order to contact you for interviews. The personal data will be processed in the form of databases and will be collected in secured personal files.

You have the option of withdrawing your application at any time.

EDS will use your personal data:

We use reasonable safeguards to limit access to your personal data to those employees at EDS seeking/considering a candidate for a position

As part of the application process and for successful candidates during your employment, we may share your data as follows:

Your data will be deleted in accordance with the applicable laws once the application process ends or if you withdraw your application.

On deletion of your personal data we may retain limited personal information to ensure that we do not contact you again in the future and where there is a legal requirement to do so.

You may choose to submit digital materials demonstrating your skills and abilities for review by EDS (“Material(s)”). Please note that Materials are not generally required. If submitted, we will use your Material only for evaluation purposes and will not distribute any copies of the Material to any third parties. We will return or destroy all copies of your Material upon completion of our review or upon your earlier request.

EDS engages in a continuous program to develop new products and ideas internally and we also regularly receive other submissions for consideration. The games, ideas or concepts that EDS develops internally or that others submit may be similar to your Material. As a result, we cannot agree to treat as confidential any Material you submit, even if it is marked as confidential or proprietary. Our acceptance or review of your Material does not imply that we will use, develop or market your Material. Our review of your Material does not prevent us from using, developing, or marketing technologies, ideas or games that may be similar in concept or idea to your Material.

Changes to Our Policy

We may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice within our products. Your continued use of our products means you accept the changes. Once you accept this policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms. If you are asked to affirmatively accept material changes to this policy and you decline to do so, you may not be able to continue to use the product provided.

Contact Us

If you have a complaint or question about this policy, you may contact us: Nicolas Sierro. (Data Protection Responsible: Nicolas Sierro)

Version 1.2