Privacy

PRIVACY POLICY

 

This privacy policy (“Privacy Policy”) explains Primal Game Studio Ltd. (“Primal”) information-gathering and dissemination practices for our website located at www.PrimalGameStudio.com and domain alias www.PrimalGS.com, and all associated sites linked to www.PrimalGameStudio.com by Primal, its subsidiaries and affiliates, including Primal company, product and service sites around the world Web site (collectively, “Site”).

Primal respects the privacy of its online visitors and users of its Site. Primal recognizes the importance of protecting information collected from users and has adopted this Privacy Policy to inform users about how Primal gathers, stores, and uses information.

We hope to provide you more and more content, but for now to stay up to date with our newest releases you can only subscribe to our newsletter. The Privacy Policy contains most of the terms that will apply once our products and services will be officially released for all (about which we will inform you via the newsletter), but we would like to inform you in advance so you can make an informed decision when you provide your consent to the processing of your personal data.

Due to strict regulations of many countries that aim to protect your privacy we can only accept your consent to our Privacy Policy if you are at least 16 years old.  If you are below 16 years of age please ask your parents or legal guardians during the registration process to give their consent to the processing of your personal data.

ACCEPTANCE OF THESE TERMS

This Privacy Policy is incorporated into and is subject to Primal’s Terms of Use for the Site. If you do not agree to the terms of this Privacy Policy or the Terms of Use for the Site, please do not provide us with any information and do not use the Site or the Site’s services. During the registration process we will ask for your (in case you are below 16 years of age your parent or legal guardians) consent for the processing of your personal data, therefore please read or make sure that your parents or legal guardians read this Privacy Policy carefully before the registration and giving the consent.

Your continued use of the Site in light of changes to this Privacy Policy will signify your acceptance of the changes for information gathered after the date of the change, however we will inform you about these changes in an email and request your consent again if necessary.

Your consent can be withdrawn at any time free of charge. Please see section CHANGE OF THE SUBMITTED INFORMATION AND OPT OUT OF THE SITE’S ACTIVITIES and YOUR RIGHT’S IN CONNECTION WITH THE DATA PROCESSING

APPLICATION OF THE PRIVACY POLICY

This Privacy Policy covers Primal’s information collection and use practices for anyone who uses the Site.

This Site, however, contains links to other websites, advertisers and other third parties. By clicking on any of these links, you are leaving the Site. A link provided on the Site does not constitute an endorsement of the content, viewpoint, accuracy, opinions, policies, products, services or accessibility of that linked website. Primal has no control over the information collected from or about you by any third party after you have left the Site. This Privacy Policy does not cover the data collection and use practices of any third party linked to Primal. Our company assumes no liability and is not responsible for any practices of such third party websites, including their privacy practices, content, or other activities. Once you link to another website from the Site, you are subject to the terms and conditions of that website, including, but not limited to, its Internet privacy policy.

PRIMAL’S COLLECTION AND USE OF INFORMATION

In order to provide you with our services, there are two methods whereby we collect information from you: passive collection of technical information and collection of personally identifiable information.

PASSIVE COLLECTION OF TECHNICAL INFORMATION

Primal automatically collects certain technical information from each visitor, including your IP address, the type of browser you use to surf the Internet, your computer’s operating system, and the website from which you accessed the Site. Your IP address tells us both your Internet Service Provider (ISP) and the general geographic location from which you are connecting. We may also use your IP address to track how long you stayed on the Site and what pages you visited. This information is used internally by Primal to help us provide a good web experience to our visitors, including providing proper formatting for our web pages and analyzing which aspects of the site are most effective.

The Site may employ cookies and other technologies such as web beacons and pixel tags. Cookies are bits of electronic information that can be transferred to a user’s hard drive to customize a person’s use of a product or online site, keep records of a user’s access to an online site or product, or store information needed by the user on a regular basis. Use of cookies is typically associated with websites.

For example, if you enter information during your session, such as age verification data, this will be stored as a cookie and you will not have to re-enter such information during that session. We may also use third party website analytic tools that employ cookies to collect certain non-personally identifiable information concerning use of our websites, such as referring website addresses, page views and browser types.

For more information please see our Cookie Policy.

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION

Personally identifiable information is information that can be used to uniquely identify a user such as name, address or credit card number. You may be asked to provide personally identifiable information during the sign in process, and then in connection with the use of the Site. While Primal collects personally identifiable information on a voluntary basis, for certain products and services Primal’s collection of personally identifiable information may be a requirement for access to the product or service or to process a user’s order.

Personally identifiable information is used internally by Primal to deliver, develop and improve products, content and services, to which users have subscribed, and to answer users’ requests.

Primal may use personally identifiable information provided by users to send them information about Primal, including news about product updates, contests, events, and other promotional materials, but only if the users agree to receive such communications. Primal will not share any of your personally identifiable information with third parties for marketing purposes without your consent.

External websites and companies with links to and from the Site may collect personally identifiable information about users when users visit their websites. Third party publishers may also collect personally identifiable information as a requirement of accessing their games or content. Primal’s Privacy Policy does not extend to external websites and companies or third party publishers with links to or from the Site. Please refer directly to these companies and websites regarding their privacy policies.

Primal may release personally identifiable information to comply with court orders or laws that require us to disclose such information. In the event of a reorganization, sale or merger we may transfer personally identifiable information to the relevant third party with the user’s consent if required by law.

CHANGE OF THE SUBMITTED INFORMATION AND OPT OUT OF THE SITE’S ACTIVITIES

You may edit the registration information that is associated with your username and email address by following the procedures outlined on the Site.

As mentioned above, you may opt-out of receiving emails from the Site when you submit your email address and by following the procedures outlined in each email.

SECURITY PROCEDURES TO PROTECT THE LOSS, MISUSE OR ALTERATION OF INFORMATION UNDER PRIMAL’S CONTROL

Primal uses industry standard security measures to protect the loss, misuse and alteration of the information under our control, including encryption and a secure server and other security measures. Nonetheless, due to the inherent dangers of the Internet, we cannot guarantee the protection of such information against loss, misuse, or alteration.

A SPECIAL NOTICE TO PARENTS OF CHILDREN UNDER THE AGE OF 12 or 16

We feel under a particular obligation to protect information obtained from young children. We would strongly urge parents to instruct their children never to disclose their real name, their address or their telephone number while they are on-line without prior permission. No information should be transmitted to Primal by minors aged 12 years or under. Primal commits to never knowingly processing data provided by minors aged 12 years or under. If you are a parent or a legal guardian and suspect that a minor aged 12 years or under who is under your custody has provided personal data to Primal please contact us on the following email address: privacy@primalgs.com or via our postal address Kacsa utca 15-23. 1. em., Budapest, 1027, Hungary. Primal will delete all personal data relating to minors aged 12 years or under after notice.

If you are an adolescent between 13-16 years we welcome you on the Site, but due to strict privacy rules and to ensure the protection of your information some addition rules apply to you.

Adolescents aged 13-16 years should ask their parents or legal guardians to read our Privacy Policy and to contact us if they would like any information on our guarantee of confidentiality or to comment on the content. Additionally, adolescents aged 13-16 years can only register on the Site if their parents or legal guardians have given their consent to the processing of the personal data of the adolescent. If you are below 16 years of age please ask your parents or legal guardians to read the Privacy Policy thoroughly after which they can give their consent to the processing of your personal data during the registration process.

Additionally, please note that some of our products may not be appropriate for adolescents under 16 years of age. Please understand that until you reach the age required by law to play with these games we cannot provide information, updates or access to these games to you.

Minors under 18 years of age should not order or subscribe to any paid service on-line without the permission of their parents or guardians. We would ask parents and guardians to be particularly vigilant and to ensure that their minors do not transgress when using our sites or on-line services.

INTERNATIONAL DATA PROCESSING AND THIRD PARTY PROCESSORS

Primal operates from Hungary, however our products and services may be provided worldwide. In order to be able to provide you with the best gaming experience and service we might need to transfer your personal data to other countries where our partners reside.

In addition, Primal may allow third parties performing services under contract with Primal, such as order or payment processors or merchandise warehouse and fulfillment services, located in and outside the European Union, to access and use personally identifiable information, but only to the extent necessary to provide those services.

Before we transfer your personal data to any third party data processors we will notify you about this and will ask for your unambiguous consent to do so in case it is required by applicable laws.

Please be informed that Primal uses IT services in relation to the Site and sending newsletters during which the data processing is carried out outside the European Union (data transfer to third country), the adequate level of data protection and the lawfulness of data processing is ensured by the EU-U.S. Privacy Shield framework agreement [Article 45(1) in the GDPR]

CHAT, FORUMS, ETC.

The Site may provide chat, forums, bulletin boards, or instant messaging tools to users. Any information that is disclosed in chat, forums or bulletin boards, or instant messaging tools should be considered public information, and users who message one another may not know each other personally. Primal has no obligation to keep personally identifiable information private that a user makes available to other users or the public using these functions. Users should exercise caution when deciding to disclose personal information in chats, forums, bulletin boards, or instant messaging tools. Users should also be aware that game play information disclosed during multiplayer game play (e.g. player name and current player statistics) is public information and may be displayed to other users.

GOVERNING LAW

This Privacy Policy is governed by the laws of Hungary.

YOUR RIGHT’S IN CONNECTION WITH THE DATA PROCESSING

You can exercise your rights stipulated in the present Point by electronic means, via the email address privacy@primalgs.com or by postal service in a letter sent to Primal, addressed to its registered seat.

At your request, Primal shall provide information [Article 5(1) in the General Data Protection Regulation (“GDPR”); right to information], in writing or by electronic means, on:

  • which data concerning to you are processed by the data controller;
  • the purposes of data processing;
  • the categories of addressees to whom Primal can disclose the personal data;
  • the period of data processing;
  • your rights and of the remedies you are entitled to.

At your request, Primal shall provide the copy of the data in a commonly used electronic form or in other form chosen by you [Article 15(3) in the GDPR; right to access and right to obtain a copy].

Primal shall modify your personal data or shall make it more accurate (rectification) according to your request [Article 16 in the GDPR; right to rectification].

You are entitled to contact Primal in order to exercise your right to access your data and in order to have his/her data rectified.

Primal shall erase your personal data if requested so by you. Primal is entitled to deny such request if Article 17(3) of the GDPR is applicable, e.g. if the personal data are necessary for the establishment or exercise of legal claims, for compliance with a legal obligation prescribed by European Union or member state law to which the controller is subject, for public interest or for exercising the right of freedom of expression and information [Article 17 in the GDPR; right to erasure].

You are entitled to withdraw your statement of consent to the processing of your personal data for the purpose of sending newsletters at any time, without restriction or reasoning, and free of charge, as well as to notify Primal of your statement for the prohibition of sending advertising material. In such case, the Primal shall erase all your personal data without delay and shall not send you newsletters thenceforth [right to the withdrawal of consent]. The withdrawal shall not affect the lawfulness of the data processing carried out prior to the withdrawal, on the basis of the consent.

You are entitled to request the restriction (blocking) of the processing of your personal data in case

  • you contests the accuracy of the personal data, for a period enabling Primal to verify the accuracy of the personal data;
  • the data processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;
  • Primal no longer needs the personal data, but they are required by you for the establishment, exercise or defence of legal claims; [Article 18 in the GDPR; right to the restriction of data processing (blocking)].

Primal shall fulfil your request for restriction by storing the concerned personal data separately from any other personal data. E.g. by saving them to an external data storage media in case of electronic databases, or by placing the data stored in paper form into a separate folder. Primal is entitled to process the concerned data, with the exception of storage, only with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a member state. Primal shall inform you before such restriction of processing is lifted.

You shall have the right to receive your personal data in a structured, commonly used and machine-readable format and shall have the right to transfer those data to another data controller. Furthermore, the Primal shall ensure, if expressly requested so by you, the direct transfer of your personal data to another data controller designated by you. [Articles 20(1) and 20(2) in the GDPR; right to data portability].

Primal shall notify you of the measure taken within one month from receiving the request. In case the request is rejected, Primal shall notify you of the reasons of the rejection and of your right to lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (“Authority”) and to seek remedy in court.

The exercise of right is free of charge. In certain cases, Primal shall be entitled to charge fee based on administrative costs or to deny taking measures on the basis of the request, in case you requests a copy of your data or if your request is manifestly unfounded or exaggerated, particularly due to repetition.

Primal reserves the right to ask you for information required to verify your identity in case it has a reasonable doubt concerning your identity. The request for a copy of your data shall be deemed a case where the above is applicable in particular, since Primal shall verify that the request was submitted by the authorised person.

Before initiating the procedures set out in the present Point, you are entitled to submit, by electronic means, your complaint to Primal in order that your concerns are eliminated and the lawful conditions are restored. Primal shall examine the complaint within one month, shall take minutes thereof, shall render a decision on the merits of the complaint and notify you of that decision in writing, by electronic means. If Primal finds the complaint well-founded, it shall restore the lawful conditions of data processing or shall terminate the data processing, including further obtaining of data or the transfer thereof. In such case, Primal shall not continue processing your data, unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claim. Primal shall notify the persons, to whom it transferred the data concerned with the complaint, of the complaint and of the measures taken on the basis thereof. The complaint procedure regulated in the present Point serves the elimination of concerns in the frameworks of communication with Primal but is not pertaining to the legal statements made with the purpose of enforcing consumer rights related to the services of Primal.

In case you consider that Primal violated your right to the protection of personal data or carries out unlawful data processing, you are entitled to initiate the procedure of the Authority. Contact details of the Authority: postal address: H-1530 Budapest, Pf.: 5.; e-mail address: ugyfelszolgalat@naih.hu; phone number: +36 (1) 391-1400; website: www.naih.hu. Additionally, you have the right to lodge a complaint with a supervisory authority in the member state where you are residing.

In case you consider that Primal violated your right to the protection of personal data, you are entitled also to initiate judicial proceedings and to claim the reimbursement of your damage arising from the unlawful processing of your data or from the breach of data security, and to claim compensation for non-material damage in case of violation of personality rights. The action shall be heard by the competent general court in Hungary. If you are a resident of Hungary you can request that, the action may be brought before the general court in whose jurisdiction your home address or temporary residence is located.

MODIFICATIONS

Primal reserves the right, at its discretion, to change, modify, add or remove portions of this Privacy Policy at any time to comply with any applicable regulations, to utilize new technologies or to improve your Primal experience, so please check back periodically to review our Privacy Policy. If Primal changes any portion of this Privacy Policy, the change will be posted in this document so that you will always know what information we gather, how we might use that information, and to whom we will disclose it. Primal will not change the use and dissemination practices related to information obtained under a prior version of this Privacy Policy without your prior consent. Please be sure to check this page periodically for changes, but in any case, we will inform you about these changes in an email.

This Privacy Policy was last changed and posted on our Site on July 17, 2018.