Privacy Policy
1. About the Company and This Document
We are TITULUM ENTERPRISES LIMITED, a Cypriot company located at Kolokotroni, 6, Floor 1, Room/Office 6, 1101, Nicosia, Cyprus (the “Company”, “we”, “us” or “our”), with the contact email [email protected].
This Privacy Policy (the “Privacy Policy”) is a document that explains what personal data we use, how exactly we use it, for what reasons we need your personal data, and what your rights are concerning your personal data.
The term “personal data” (the “user data”, “data”) is used within the meaning outlined in the General Data Protection Regulation (the “GDPR”), in view of existing international practices on personal data protection in countries that provide an adequate level of such protection. It includes any information that relates to or identifies you directly or indirectly.
2. Why We Prepared This Document
We prepared this document to provide you with essential information concerning the personal data we collect through our website https://warspear-online.com/ (the “Website”), meaning the website where this Privacy Policy is located, including our forum on the Website (the “Forum”), or through our online game “Warspear Online” (the “Game”), the information about which is located on the Website.
The Website and the Game can collectively be referred to as the “Products”.
By using or accessing the Products, you confirm that you have read, understood and accepted this Privacy Policy. Please ensure you have read it carefully, particularly the section detailing your rights about the personal data we collect about you. If you do not agree with this Privacy Policy, you should not use our Products.
We collect personal information such as customer account data (e.g., your contact information) directly from you, when you act as both a user of the Game or the Website visitor.
Here are the basic provisions of how the Company views data privacy:
- We do not collect any data without your consent, legitimate interest or for purposes other than performance of our contract with you.
- We collect data only on lawful grounds.
- We collect only a minimum amount of information, needed to perform the contract or to take measures before entering into a contract, or protect our legal interest.
- We do not monetize your data.
- We do not check the user information received from you, except where such a check is necessary for us to fulfill our obligations to you.
- We process your personal data as transparently as practically possible.
By providing access to our Products, we, acting reasonably and in good faith, believe that you:
- Have all the necessary rights to use our Products.
- Provide true, accurate, up to date and complete information about yourself.
- Are at least 16 years of age or over the minimum age in the relevant territory, or your parents agree that you can use our Products.
- Are aware of and accept this Privacy Policy.
3. Our Reasons and Purposes to Collect Personal Data
We collect personal data for specific purposes and we will use this data exclusively for the specified purposes.
The purpose of the personal data we collect is so we can perform a contract, take measures before entering into a contract or protect our legal interest. Personal data can also help us improve our Products for our users.
All the personal data we process is lawfully obtained and on a legal basis.
If the relationship between us and you changes, we may need more information. For example, if you fill out a form to request more information about our Products, we will use your contact data to send the requested information to you.
We normally collect personal data from you only when we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have the legal obligation to collect personal data.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at that time and advise you whether the provision of your personal data is mandatory or not (as well as explain the possible consequences if you do not provide your personal data).
Similarly, if we collect and use your personal data based on our or a third party's legitimate interests and those interests are not already listed above, we will ensure that the nature of those legitimate interests are made clear to you at the time.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details indicated in this Privacy Policy.
The list of purposes for which we request or use your data, the scope of such data, and other important details are specified in Section 4 of this Privacy Policy.
4. What Personal Data We Collect
The Company requires the minimum amount of data necessary to provide you access to the Products. The amount or type of data we collect depends on the Product (Website or Game) and how you use it. If you choose to share additional information with us so that we can better customize your account and our Products, we will process it with the same care and respect. We do not sell your personal information or share your information with third parties in the business interests of such third parties. We use the information we collect and share it with our service providers primarily to provide you access to our Products and, as required, for our operational purposes (e.g., to perform actions needed for us to function as a business, such as to collect payments). In addition, we may use data about our users to detect, prevent or investigate security incidents, fraud or abuse and misuse of our Products.
We never collect more data than we need and may ask for additional data, when needed. The personal data we collect when you use our Products can be divided into three main categories. We use it to understand who is using our Products and find ways to detect, prevent and investigate fraud, abuse, or security incidents.
Depending on our relationship, the personal data we collect when you use our Products may include:
| User | Purpose of processing | Scope of personal data |
|---|---|---|
| Game |
|
|
|
||
|
||
|
||
|
||
| Website |
|
|
|
||
|
||
|
||
| Forum |
|
|
Processing Method and Timing
The processing of personal data is carried out with the use of automation tools.
Time limits for the processing and storage of personal data: until the purpose of processing is achieved, unless another time limit is stipulated by the agreement or applicable law, and/or until you request the data to be deleted.
Special Category Data
Certain categories of personal information have additional protection under the GDPR. These categories include information about your health, racial or ethnic origin, etc.
The Company does not store or process such special categories of personal data.
5. Cookies
Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors to their websites. A cookie contains a unique number, which is used to recognize your computer or mobile device when you return to our Website. Cookies can remain on your computer or mobile device for varying periods of time. The cookies can be either “persistent” cookies or “session” cookies. Persistent cookies are stored by a web browser and remain valid until a set expiration date. Session cookies only exist while your internet browser is open and are automatically deleted once you close your browser.
Web beacons are small electronic files contained on pages of websites that permit companies to count the number of users who have visited certain web pages on a website and are used for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).
Cookies are used to ensure the Website works correctly.
We use a variety of cookies for different purposes. Specifically, we use cookies to enhance the experience of our visitors to the Website and to better understand how the Website is used. Cookies may tell us, for example, whether you have visited the Website before or whether you are a new visitor.
We also use cookies to prevent unlawful actions performed by malicious software.
There are several categories of cookies that we can use:
- Essential and security cookies, web beacons and other tracking technologies are necessary for the operation of the Website. These tracking technologies enable you to move around the Website and use the Website's features. You cannot opt out of these types of cookies because they are required for the operation of the Website and service.
- Analytics cookies, web beacons and other tracking technologies collect information about how you have used the Website. These items help us to understand how the Website performs, how visitors interact with the site and whether there are any technical issues. This storage type usually does not collect information that identifies a visitor.
- Personalization cookies, web beacons and other tracking technologies. These items allow the Website to remember the choices you make (such as your username, language or the region you are in) and provide more personal, enhanced features. We use personalization cookies, web beacons and other tracking technologies to improve the user experience with our Website.
- Marketing cookies, web beacons and other tracking technologies are used on our Website by third-party service providers. These cookies help measure the effectiveness of our advertising campaigns. They are used to make adverts more relevant to your preferences and to analyze Website visits and ad conversions from third-party websites.
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| td | Registers statistical data on users' behavior on the website. Used for internal analytics by the website operator. | Session | Analytics | |
| _ga, _ga_# | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years | Analytics | |
| ads/ga-audiences | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behavior across websites. | Session | Marketing | |
| _gat | Used to send data to Google Analytics about the visitor's device and behavior. | A day | Marketing | |
| collect | Used to send data to Google Analytics about the visitor's device and behavior. | Session | Marketing | |
| _gid | Used to send data to Google Analytics about the visitor's device and behavior. | A day | Marketing | |
| rc::a | This cookie is used to distinguish between humans and bots. | Persistent | Necessary | |
| rc::c | This cookie is used to distinguish between humans and bots. | Session | Necessary | |
| _gcl_au | This cookie is used to store and track conversions. | Session | Necessary | |
| metrika_enabled | Titulum | Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences. | Session | Marketing |
| CookieConsent | Titulum | Stores the user's cookie consent state for the current domain. | A year | Necessary |
| ci_session | Titulum | Used by the server to deliver the content and functionality of the website. | 20 days | Necessary |
| user_lang | Titulum | Determines the preferred language of the visitor. | 20 days | Necessary |
| yandexuid, ymex | Yandex | Registers data on visitors' website-behavior. This is used for internal analysis and website optimization. | A year | Analytics |
| _ym_retryReqs, _ym3:0_reqNum | Yandex | Registers statistical data on users' behavior on the website. Used for internal analytics by the website operator. | Persistent | Analytics |
| yp | Yandex | Sets a unique ID for the session. This allows the website to obtain data on visitor behavior for statistical purposes. | A year | Analytics |
| _yasc | Yandex | Collects data on the user across websites. This data is used to make advertisement more relevant. | 10 years | Marketing |
| bh | Yandex | Collects data on user behavior and interaction in order to optimize the website and make advertisement on the website more relevant. | A year | Marketing |
| receive-cookie-deprecation | Yandex | Collects information on user behavior on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. | A year | Marketing |
| yuidss | Yandex | Collects information on user behavior on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. | A year | Marketing |
| _ym_d | Yandex | Contains the date of the visitor's first visit to the website. | A year | Marketing |
| _ym_synced | Yandex | Tracks the user's interaction with the website's search-bar-function. This data can be used to present the user with relevant products or services. | Persistent | Marketing |
| yabs-sid | Yandex | Registers data on visitors from multiple visits and on multiple websites. This information is used to measure the efficiency of advertisement on websites. | Session | Marketing |
| _ym_visorc | Yandex | Saves information of actions that have been carried out by the user during the current visit to the website, including searches with keywords included. | A day | Marketing |
| _ym_uid | Yandex | This cookie is used to collect non-personal information on the visitor's website behavior and non-personal visitor statistics. | A year | Marketing |
| _ym_isad | Yandex | Used by to determine whether a user has ad blockers. | A day | Marketing |
| sync_cookie_image_decide, sync_cookie_image_finish, sync_cookie_ok | Yandex | Used for data-synchronization with advertisement networks | Session | Marketing |
| yashr | Yandex | Used to generate statistical data on how the visitor uses the website. | A year | Marketing |
| __ym_tab_guid | Yandex | Tracks the user's interaction with the website. | Session | Marketing |
| _ym#_lastHit | Yandex | Tracks the user's interaction with the website. | Persistent | Marketing |
| _ym#_lsid | Yandex | Tracks the user's interaction with the website. | Persistent | Marketing |
| _ym_wv2rf:#:0 | Yandex | Tracks the user's interaction with the website. | Persistent | Marketing |
| webvisor/# | Yandex | User behavior statistics. | Session | Marketing |
| i | Yandex | Used to identify visitors. | A year | Necessary |
| sync_cookie_csrf | Yandex | Used in connection with the synchronization between the website and third-party Data Management Platform. The cookie serves to monitor this process for security reasons. | A day | Necessary |
It is your choice as to whether or not to accept cookies. Most browsers allow you to configure the browser settings so that cookies from websites cannot be placed on your computer or mobile device. If you choose not to accept cookies, you may be able to continue browsing our Website, but we may not be able to provide you with certain features.
Please note that the Website will not work properly if cookies are blocked.
6. Transfer and Storage of Your Personal Data
Personal data we collect can be stored and processed for the purposes set out in this Privacy Policy in any country in which we operate and your personal data may be transferred, stored and processed by recipients in numerous countries worldwide where our servers are located and our databases are operated. We do everything that is required to make sure all recipients of your personal data understand the necessity to process personal data only on a legal basis in line with any and all applicable legislation.
Our servers are located in the European Economic Area (EEA).
We do not sell your personal information or the personal information of your end users. We also do not allow any personal information to be used by third parties for their own marketing purposes (except in cases where you explicitly request or provide consent for us to do so, such as at a conference when you direct us to share your information with a sponsor). However, we do need to share personal data in order to provide our Products to you, such as to route a call you send through us or to store data you ask us to store. The scenarios under which we may share your data with third parties are detailed below.
We may transfer your personal data to the following third parties' categories:
- Any third party to whom we assign or novate any of our rights or obligations under a relevant agreement.
- Any national or international regulatory, enforcement, exchange body, central or local government department or other statutory or public body or court where we are required to do so by the applicable law or regulations at their request.
- Third parties, if you have expressed your consent to such transfer of your personal data, if required for you to use certain services or performance of a particular agreement or contract with you.
- Third parties involved in the fulfillment of our obligations (including hosting providers, etc.).
| Third-party | What it does | More information |
|---|---|---|
| AppsFlyer | AppsFlyer provides services for marketing and analytic purposes to improve user experience in the app and enhance fraud protection. | https://www.appsflyer.com/legal/processingcustomer-data/ https://www.appsflyer.com/legal/privacy-policy/ |
| Google Analytics | Google Analytics helps us to understand how website visitors engage with it. | https://policies.google.com/technologies/partner-sites https://policies.google.com/technologies/cookies https://support.google.com/analytics/answer/6004245 |
| Ensures that users can quickly and securely login to the app and share some data between the app and Facebook account in accordance with user permissions. | https://developers.facebook.com/docs/facebooklogin/#------------facebook | |
| Freshworks | Provision of technical support. | https://www.freshworks.com/privacy/ https://www.freshworks.com/list-of-cookies/ https://www.freshworks.com/privacy/data-hosting/ |
| Yandex.Metrica | Used to obtain data on site traffic/mobile app traffic. | https://yandex.com/legal/metrica_termsofuse/ https://yandex.com/legal/metrica_agreement/ |
7. International Data Transfers
The use of our Products often involves the transfer of personal data to recipients and third parties both inside and outside the European Economic Area (EEA). We take care to ensure our partners regardless of location have sufficient safeguards in place to properly process and protect your personal data in line with our own data protection and information security standards.
One of the important steps we take when it comes to international data transfers involving third parties is due diligence and vetting. As part of the third-party vetting process, we ensure that personal data will only be transferred to a third party located outside the EEA with the required cross-border transfer mechanism and safeguards in place. This means that when we engage a third party that is located outside of the EEA, we agree on the appropriate level of data protection, including additional contractual, technical and organizational measures and the execution of a transfer impact assessment where necessary, to ensure the ongoing protection of the rights and freedoms of all individuals, inside and outside the EU. We consistently monitor changes to the international transfer mechanisms permitted under applicable privacy laws to ensure ongoing compliance with international data protection standards.
We may transfer and store your personal data to third-party data processors located in countries outside of the EEA. We only transfer your personal data to third parties for which we can be sure that we can protect your privacy and your rights. For example, if the third party is located in a country which the EU has deemed to have adequate data protection laws in place or a country which has not been recognized by the European Commission as providing an adequate level of personal data protection but where we have a contract in place with that third party which includes the European Commission's standard data protection clauses.
Whenever we send data to countries that do not provide the same level of protection as the GDPR (to countries that have not been recognized by the European Commission as providing an adequate level of personal data protection), we employ the appropriate safeguards to protect your personal data, including but not limited to Standard Contractual Clauses for Processors.
Accordingly, by using our Products, you authorize the transfer of your information to countries that have not been recognized by the European Commission as providing an adequate level of personal data protection, where our service providers process data for customer care, account management and service provisioning, and to other locations where we and/or our service providers operate, and to its storage and use as specified in this Privacy Policy and any applicable terms of service or other agreement between you and the Company or between you and our customers.
8. How We Protect Your Personal Data
We apply a variety of measures to safeguard the collection, transmission and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Even so, no security measure is 100% perfect. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use of your information under our control.
Notwithstanding the foregoing, to protect your personal data we have the physical, electronic and procedural means of protection in accordance with international standards. We use encryption to keep your data confidential when it is transferred. We review, verify and update our methods for collecting, storing and processing information, including physical security measures, to prevent unauthorized access to our systems. We restrict access to personal data to our employees who need this information to process it. Anyone who has such access is subject to strict contractual obligations regarding confidentiality and may be subject to disciplinary action if they do not fulfill these obligations.
9. Your Rights in Relation to Personal Data
You have many rights relating to your personal information and how it is used. Below are your major rights (depending on how we collected your personal data) and how you can make use of these rights:
- Right to access your personal data: At any time, you can ask us what personal data we have, what we do with it, why we process it, who we have shared it with, etc. You also can ask us to give you a copy of the personal data undergoing processing. To request access, email us at [email protected] with the title “Subject Access Request”.
- Right to rectify your personal data: At any time, you can request that we update, block or delete your personal data if the data is incomplete, outdated, incorrect, unlawfully received or no longer necessary to process. If you do not provide correct personal data, we can suspend access to our services.
-
Right to erasure: At any time, you can ask us to delete all your personal data that we have – it is your right to be forgotten, as if we had never met. If you do so, you will no longer have access to our Products.
However, we are entitled to not erase your personal data and process it insofar as the processing is permitted by the applicable law on personal data (including, but not limited to, for settling claims and disputes and responding to requests from state authorities). - Right to restrict the use of your personal data: If you think, for instance, that your personal data is not accurate and we need to check it, we can pause the processing of your personal data while we clarify if it is accurate or not.
- Right to object to the processing of your personal data: At any time, you can tell us to stop and we will no longer process your personal data, but we can retain it if there are legitimate grounds to do so. If you do this, you will no longer have access to our services.
- Right to data portability (in certain specific circumstances): You can ask us to download (export) all personal data that we have in an acceptable format to give it to someone else or ask us to give them your data directly.
- Right not to be subject to an automated decision: If we process your personal data automatically and we make some decisions according to it and it affects you in any serious way, you can express your point of view and contest such a decision. But in reality, we do not do this.
- Right to lodge a complaint with a supervisory authority: At any time, you can complain about us and about how we are processing your personal data.
Before we process any request, we may ask you for certain information in order to verify your identity. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond to your requests in a reasonable timeframe.
If you are a citizen of the European Union, have the right to protection of your personal data as specified in the GDPR.
10. Retention Periods
We will retain your personal information for as long as required for purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information for a period of time that is required and/or permissible under the applicable/relevant law.
Also, we may keep information relevant to the resolution of any disputes, to enforce our agreements with you and provide you with the ability to use our products, to protect our or your legal rights, and to comply with technical and legal requirements and constraints related to the security, integrity and operation of our products.
11. Policy Changes
We may update this Privacy Policy from time to time. The new version of this Privacy Policy will be published on our Website. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes. Also, we may notify you via any applicable communication channels.
Your continued use of our Products means that you accept and agree to the changes.
If we make changes that affect your rights, we will provide advance notice to you, such as by posting a message on the Website, or we will send an email to the address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice and seek your consent to any material changes if this is required by applicable law.
12. Contact Us
If you have a complaint or question about this Privacy Policy, if you would like to make a request concerning your personal data, or withdraw your consent, you can contact us at any time at [email protected]. We will aim to respond to you within a maximum of 30 calendar days from receipt of the request.
All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than to respond to the enquiry, except as expressly provided by law.