Privacy and Cookie Policy

Please, also review our updated Terms of Service and Terms and Condition of Sale  Terms and Condition of Sale  updated to November 23, 2024.


Last modified: November 23, 2024


DATA CONTROLLER

SANTER HELMUTH (herein after “SH”), VAT number IT01585030214, based in Via Gegend 28, 39010 San Pancrazio (Bolzano), Italy.

E-mail address of Data Controller: emberveilgames [at] gmail [dot] com  


DATA COLLECTED

Among the Personal Data collected by the Apps of emberveilgames.com (herein after generally referred as “emberveilgames.com”) independently or through third parties, there could be: email; User ID; first name; last name; date of birth; country; city; payment information; billing address; Tax ID; order ID; shipping address; Usage Data; Tracking Tools; device information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); session duration; page scrolling interactions; clicks; time zone; mouse movements; interaction events; diagnostic events; page events; custom events; layout details; location information; phone number; ZIP code; gender; physical address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the Data collection itself.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of emberveilgames.com.

Unless otherwise specified, all Data requested by emberveilgames.com is mandatory. If the User refuses to provide them, emberveilgames.com may not be able to provide the Service. In cases where emberveilgames.com specifically states that some Data is optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Data Controller.

Any use of Cookies - or other tracking tools - by emberveilgames.com or by the owners of third-party services used by emberveilgames.com is aimed at providing the Service requested by the User, in addition to any other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through emberveilgames.com.


METHODS AND LOCATION OF DATA PROCESSING

  1. Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.

Processing is carried out using computers and/or IT-enabled tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of emberveilgames.com (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

  1. Location

The Data is processed at the operational headquarters of the Data Controller and in any other location where the parties involved in the processing are located. For further information, please contact the Data Controller.

The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information about the location of processing, the User can refer to the section related to the details of Personal Data processing.

  1. Retention Period

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on User consent.

  1. Purpose of Data Processing

User Data is collected to allow the Data Controller to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify fraudulent activities, or malicious activities, as well as for the following purposes: Registration and Authentication, Payment Management, Displaying content from external platforms, Traffic Optimization and Distribution, Remarketing and Behavioral Targeting, Heat Mapping and Session Recording, Advertising, Statistics, Contacting the User, RSS feed management, Access to third-party accounts, and Creation and management of emberveilgames.com.

  1. Cookie Policy

emberveilgames.com does not use cookies, sessions or any other tracking technologies to collect or store user data. If you notice cookies are set it might be a result of caching. Caching is essential and helps websites load faster for returning visitors by storing certain information locally on their devices. These cookies do not store any personal information about you.


THIRD-PARTY SERVICES AND SHARING OF INFORMATION

emberveilgames.com utilizes the following third-party services and may share your information with the service provided. We encourage you to review their policies periodically for updates. 

Please note that we are not responsible for the privacy practices or content of these websites. Please review the privacy policies of third-party services you may access through our game or website.

emberveilgames.com uses Google Fonts. Google Fonts is a service that provides fonts to websites. To improve user experience, your IP address may be transferred to Google when using these fonts. Google claims it uses limited data and does not use this information for personal identification or profiling.


ADDITIONAL INFORMATION FOR USERS

  1. Legal Basis of Processing

The Data Controller processes Personal Data concerning the User if one of the following conditions exists:

  • - The User has given consent for one or more specific purposes.
  • - Processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures.
  • - Processing is necessary to comply with a legal obligation to which the Data Controller is subject.
  • - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

However, it is always possible to ask the Data Controller to clarify the specific legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract, or necessary to conclude a contract.

  1. Further Information on Retention Period

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on User consent.

Therefore:

  • - Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract is fully performed.
  • - Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained as long as needed to fulfill such interests. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on User consent, the Data Controller may retain Personal Data longer until such consent is revoked. Additionally, the Data Controller may be obliged to retain Personal Data for a longer period to comply with a legal obligation or an order from an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this period, the right to access, delete, rectify, and the right to data portability can no longer be exercised.

You can request to delete your account and information by following this guide: How to delete your Account in EmberVeil Games 


USER RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

Users can exercise certain rights with respect to the Data processed by the Data Controller.

In particular, within the limits provided by law, the User has the right to:

  • - Withdraw consent at any time. The User can withdraw previously given consent for the processing of their Personal Data.
  • - Object to the processing of their Data. The User can object to the processing of their Data when it is done on a basis other than consent.
  • - Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the processed Data.
  • - Verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
  • - Obtain the restriction of processing. The User can request the restriction of processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.
  • - Obtain the erasure or removal of their Personal Data. The User can request the erasure of their Data by the Data Controller.
  • - Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred to another controller without any hindrance.
  • - Lodge a complaint. The User can lodge a complaint with the competent data protection authority or take legal action.

Users have the right to obtain information regarding the legal basis for the transfer of Data abroad, including to any international organizations governed by international law or established by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect their Data.

  1. Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users have the right to object to processing for reasons related to their particular situation.

Users are reminded that if their Data is processed for direct marketing purposes, they can object to that processing at any time, free of charge, and without providing any reasons. If Users object to processing for direct marketing purposes, their Personal Data will no longer be processed for such purposes. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

  1. How to Exercise Rights

To exercise their rights, Users can make a request to the contact details of the Data Controller provided in this document. The request is free of charge, and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectifications, deletions, or restrictions on processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of such recipients upon request.


FURTHER INFORMATION ON PROCESSING

  1. In-game data

User in-game data such as username, level, rating, amount played, avatar and other metrics or info (collectively referred as “in-game data”) shall be collected, processed and used by the Data Controller including, but not limited, for the organization of Promotions and the composition of the Leaderboard. Please, be aware that your in-game data will be made public and accessible within emberveilgames.com.

  1. Legal Defense

User Personal Data may be used by the Data Controller in court or in the stages leading to possible legal action arising from improper use of emberveilgames.com or related services by the User. Users declare themselves to be aware that the Data Controller may be required to reveal Data upon request of public authorities.

  1. Specific Information

Upon request of the User, in addition to the information contained in this privacy policy, emberveilgames.com may provide the User with additional and contextual information regarding specific services, or the collection and processing of Personal Data.

  1. System Logs and Maintenance

For operation and maintenance purposes, emberveilgames.com and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User's IP address.

  1. Information Not Contained in this Policy

More information concerning the processing of Personal Data may be requested at any time from the Data Controller using the contact information.


CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page and, if possible, on emberveilgames.com, as well as by notifying Users via one of the contact details available to the Data Controller. Please, therefore, check this page frequently, referring to the date of the last modification indicated at the bottom.

If changes affect processing activities whose legal basis is consent, the Data Controller will collect User consent again, if necessary.