PRIVACY POLICY

Argosreal Games E Studio Ltda, (“we,” “us” and “our”), is a developer, publisher and marketer of interactive entertainment. This Privacy Policy explains our data practices for the products, services, and websites (collectively the “Services”) that we offer to consumers.

1) Scope of this Policy and Who We Are.

This Privacy Policy applies to Argosreal Games E Studio Ltda. Please read this Privacy Policy carefully. The Services also are subject to our Limited Software Warranty and License Agreement (“EULA”), Terms of Service, and any other policies included in our Services. This Privacy Policy supplements privacy disclosures provided with your software product and from your console manufacturer.

2) Information We Collect and Our Lawful Bases for Processing.

You provide us with information directly, such as when you set up an account with us. We also collect information about you and your activity when you use our Services – whether through gaming consoles, computers, mobile devices, in-game applications, software platforms, third party social or gaming networks. We may use online tracking, such as cookies and similar technology, to collect information, when you share in-game content with friends, or connect to our Services, and we collect information from third parties (such as advertising networks and external business partners).

The types of information that we collect depend on how you use the Services and interact with us. You can control the personal information we collect from you unless we need it for the requested activity (e.g., to provide the Services you’ve requested or purchased, to confirm who you are, or to participate in an event). We will let you know when information is necessary.

Information You Provide. You provide us with information when you use the Services, such as when you:

a) Create an account, or register for or use the Services;
b) Subscribe to newsletters and communications;
c) Comment on our message boards, forums, chat rooms, feeds, sites, or other Services;
d) Purchase or redeem one of our products or services, including physical items, virtual items, virtual currency, or add-ons;
e) Download, install, or access demos, programs, or other software;
f) Contact us for support or other purposes;
g) Use our email / share features;
h) Participate in events, contests, promotions, or surveys; or
i) Participate in an activity where you can provide, or need to provide, your information.

Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, hardware configuration, console ID, software products played, survey data, IP address, geolocation, and the systems you play on. We combine this information across computers or other devices that you use.

Gameplay Information:

When you use the Services on hardware connected to the Internet, we receive information about your gameplay even if you are not specifically notified at the time or do not take any actions to actively give us this information. Gameplay information includes your console ID, gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device ID, other console / device information, and other information and statistics regarding your Service use. We collect gameplay information even if you do not register for the Services and we may collect gameplay information while you are offline. Offline gameplay information is transmitted to us when you next connect to the Internet. We may combine gameplay information with other information we have about you.

Console, Gaming and Social Networking Information:

We collect information when you use third-party platforms like a gaming console account, gaming network service account, or social networking service account to connect to or engage with our Services. When you use these third-party platforms or link your Argosreal Games account, the third-party platforms provide us with information about you. For example, depending on your use of, or activity on the third-party platform, we receive your user name, your friends list, or account information necessary to provide a purchased in-game item. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.

Information from Third Parties:

We receive information from third parties to update the information that we collect about you. For example, we receive information from public databases, console manufacturers, analytics providers, game developers, and other business partners that includes demographic information and information about your interests. We obtain information from social media and other publicly available sources, which we may use to better understand our users or to seek intelligence about breaches of our Terms of Service. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on our message boards, forums, chat rooms, or other Services, or an individual sends us a direct message, for example, about an alleged breach of our Terms of Service.

We collect, use, and otherwise process your information when we have a lawful basis, as follows:

a) Consent: We ask you for consent to collect or use your personal information for specific purposes, such as when we want to send you emails about special offers or competitions, or if you decide to link your Argosreal Games account with a third-party service.
b) Contract Performance: We process your personal information when we need to perform and manage a contract with you, such as our Terms of Service, or to take steps at your request before we contract with you, such as to complete transactions with you and to allow you to play our games online.
c) Legal Requirement: We process your personal information when required by law.
d) Legitimate Interest: We process your personal information when necessary for our, or others’, legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our products and services; performing analytics and using surveys to better understand our users; conducting direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; ensuring the proper function, security, and integrity of our services; dealing with user questions; enforcing our Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of our EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement.

3) Cookies and Similar Technology.

Cookies are very small text files that companies place on your device when you visit or use some sites, applications, or other web-based services to help identify a computer, browser, or device. We use cookies, web beacons, Internet log files, and similar tracking technologies (ours and from third-party providers) to allow our Services to function; maintain your preferences and settings; provide enhanced features; analyze how users use our Services; combat fraud; prevent violations of our EULA and policies; and to provide you with targeted advertising based on your interests. If you choose to provide us with information, it may be linked to the information collected by cookies and similar technologies including advertising cookies. Our system may not respond to Do Not Track requests or headers from some or all browsers. The Manage Your Account, Communications, and Data section below provides additional information about our use of cookies and similar technologies and your ability to manage cookies You may also use the cookie preference tool, where available, or visit the cookie policy posted on the Service for more information.

Cookies:

Cookies are used to identify a computer, browser, or device. Certain cookies are necessary for the Services to function and others let us to provide you with an enhanced experience. You can disable cookies on your device or set your browser to alert you when we or others send cookies to your device but disabling cookies may affect your ability to use certain Services. For more information, including details of specific cookies we use, applicable for the Service, see the cookie preference tool or visit the cookie policy posted on the Service you are visiting.

Internet Log Files:

We may collect Internet log files when you use the Services. These log files can include IP addresses, MAC addresses or other device IDs, depending on your network configuration. Depending on the Service you use or the activity you engage in, we associate these log files with your information.

4) How We Use Information.

We use the information we collect from and about you within Argosreal Games E Studio Ltda for a variety of business purposes including to: provide the Services; fulfill orders and requests; analyze and improve our Services and our business; communicate with you; respond to questions or technical problems; develop internal marketing and demographic studies; provide support and security for our products; and as more fully described in this Privacy Policy.

We also use your information within Argosreal Games E Studio Ltda for commercial purposes, including: send you and similar consumers direct marketing and online / social media advertising from Argosreal Games E Studio Ltda and our business partners, including use of demographic information; for other purposes identified when you provide your information; or otherwise with your permission. We may further use your information as permitted by law.

If you participate in open communities, such as online gaming sessions and social networking services, we automatically post certain information, such as your user name or ID and gameplay statistics, within the game, on social networking services, on our Services, or on specialized game sites. If you participate in tournaments or other online game events, we must publicly post your information. We also use automated means to monitor gameplay to ensure that you and others use our Services in accordance with applicable policies, including our EULA and Terms of Service. If we find that you have breached our Terms of Service or other applicable policies, this could lead to your temporary or permanent exclusion from the Services.

We use information we collect from and about you for business purposes including to:

a) Provide the Services;
b) Fulfill product orders and other requests, respond to your questions, and communicate with you;
c) Enhance your experience on the Services, including to recognize you, maintain your preferences and settings, and link to your third-party console, gaming, and social networking platforms;
d) Provide technical and other support;
e) Review the use and operations of the Services, develop new products or services, and conduct analyses to enhance or improve our software, content, internal marketing, support, and Services;
f) Conduct internal marketing and demographic studies;
g) Analyze our users, in combination with other data, to assess our user base and target marketing at other similar groups;
h) Address issues with the Services or other business needs;
i) To protect the security or integrity of the Services and our business such as by protecting against and preventing violation of our EULA and policies, including combating fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and managing risk exposure; and
j) Interact on your behalf with the third-party console, gaming and social networking platforms you connect with our Services.

We use information we collect from and about you for commercial purposes, including to:

a) Provide you and other users like you with customized content on the Services, targeted offers and advertising on the Services, via email and text message, or on other sites, mobile applications, or social media on behalf of Argosreal Games E Studio Ltda or our business partners; and
b) Contact you with information, newsletters, and promotional material.

We also use information we collect from and about you to:

a) Participate in other processing that we inform you about when you provide your information or when you consent to such processing; and
b) As permitted by law.

We use the information we collect from Argosreal Games E Studio Ltda as follows.

If you use certain Services, such as the Argosreal Club, we may automatically enter you into contests based on your membership or use of the Services.

Some third-party services also let you post information about your game activity to their sites to share with others. If you use these features, those third-party services’ privacy policies and terms govern your actions on those sites and the information that those services collect.

5) When We Share Information.

As detailed in this Privacy Policy, we share your information with our vendors that perform support and other services in connection with the Services; advertising service providers and advertising partners that enable us to conduct and display advertising on the Services and third-party sites, mobile applications, or social media services; and with third parties for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, for use in aggregate or anonymous form, and for other purposes with your permission.

Advertising:

We use Argosreal Games E Studio Ltda and third-party advertising to support our Services, such as ad networks, data exchanges, traffic management service providers, social networks and marketing analytics service providers. These providers use cookies and similar tracking technology to collect information about your device and your Service use. This information, along with information that we share with them, enables us or our providers to recognize you or your device and to serve ads to you or your device. This includes, as relevant, your device type; IP address; MAC address or other device ID; a secured (hashed) version of an email address you have provided to us; gaming console ID; IDFA, Android ID, or other advertising ID; gaming network service account; browser type and version, character set, screen size and color; language; operating system and version; font packages installed; geographic location; types of pages, content and ads viewed on the device; frequency of and time spent during your visit; and information about your use of a site or Service.

We and sometimes our providers, collect or share this information when you use our Services, click on a site or an ad, or launch one of our games or other mobile applications.

Third Parties:

We share your information with third parties as described in this Privacy Policy, including as follows:

a) Collaborative Relationships: When we offer services or promotions in collaboration with a third party who will receive your information for its own use, we will inform you of that at the time of collection and you may choose whether to participate in the offering.
b) Legal & Safety: We may share your information to protect the security of our Services, servers, network systems, databases, and business and in connection with an investigation of fraud, intellectual property infringements, interference with our rights, property or users, or other activity that is illegal or may expose you or us to legal liability, including as required or requested by law enforcement or other government officials. We also may share your information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or when we believe that it is necessary to protect our rights, investigate, or enforce our policies, terms, combat fraud, or comply with a judicial proceeding, court order, or legal process served on Argosreal Games E Studio Ltda. We also may share your information when we have reason to believe it is necessary to investigate or enforce our policies, terms, or other legal document or contract related to the Services or rights of a third-party.
c) Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business. We may disclose information about you and transfer that information to another entity as part of a potential or actual acquisition or merger of Argosreal Games E Studio Ltda or any of our assets. If we bring or are defending a reorganization, bankruptcy, or similar event, such information may be considered our asset and sold or transferred to third parties.
d) Aggregate or Anonymous Information: We may share aggregate or anonymous information with third parties for their marketing or analytics uses. This information cannot be used to identify you.
e) As Disclosed to You: We may share your information as disclosed to you at the time of collection.

6) Manage Your Account, Communications, and Data.

We provide several options for you to manage your Service account, communications you receive from us, and how we use your information. These include through the settings in your Service account; utilizing email unsubscribe and deletion tools; opting out of interest-based ads; and, depending on your location, making a data request or exercising your right to object to our use of your personal information. This can include, in some countries, a right to object to our use of your data.

Service Accounts:

You can manage how we use your personal information and the communications that you receive from us by logging into your Service account and using its account and privacy settings.

Email Unsubscribe:

If you have subscribed to a marketing or newsletter list from Argosreal Games, you can unsubscribe from that list using the unsubscribe link that is provided in the email.

Argosreal Club:

To delete your Argosreal Club account or, depending on your location, submit a request to object, delete, restrict, correct, or receive a copy of the personal information collected about you by Argosreal Games E Studio Ltda.

If you are unable to log in to your Argosreal Club account, or you do not have access to your Argosreal Club account, and wish to delete your Argosreal Club account, please email support@argosrealgames.com from the same email account you used to join Argosreal Club, include your Argosreal Club nickname in the message, and include “Delete Account” in the subject line.

As described in the How We Use Information section above, when you use certain features your activity is public. Even if you delete your account or data, some activity information may still appear, including on certain gameplay boards including those hosted by third parties, such as console manufacturers.

8) Children’s Privacy.

Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 18 years old. We may direct certain Services to an audience of all ages. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent’s permission to collect personal information from children. If we become aware that a child has provided personal information without a parent’s permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.

9) Data Security.

We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.

10) International Transfers.

We may process, transfer, and store information about you in connection with the Services in Brazil and other countries that may not have data protection laws equivalent to the country where you reside. We take steps to apply appropriate safeguards when we transfer that information.

When your information is in another country, it may be accessed by the courts, law enforcement, and national security authorities pursuant to the laws of that country. If you reside in the UK, EU, EEA or Switzerland, we rely on Standard Contractual Clauses and/or other approved legal mechanisms to transfer personal information from the UK, EU, EEA or Switzerland to countries located outside of these locations.

11) Public Postings.

If you share personal information, post an image or video, or provide other content in public forums such as on a message board, chat room, comment field, or profile page, other people can view, collect, and use that information. If your user name or ID contains your real name, then you acknowledge that your name will be made publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may be able to identify you, use the information to send you messages, or copy any of the images, video or content you have shared. There is no expectation of privacy or confidentiality on any of these public forums. You are strongly encouraged not to share your personal information in public forums or in your user name or ID. You are responsible for any information or content you publicly post using our Services.

12) Changes to Privacy Policy.

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to ensure that you are aware of these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.