NOTICE OF THE USE OF PERSONAL DATA FOR OTG PIONEERS PROGRAM TEST

This notice (“main privacy notice”) aims to give you information on how POSEIDON 133 PTE. LTD. and its affiliates (“Gunzilla”, “we”, “us”, “our”) will collect and process the following categories of personal data about their potential players for the purpose of the OTG Pioneers Program test (the “Pioneers Program”) selection at Gunzilla:

-      your User ID;

-      your watermark with logged in User ID;

-      your Epic Account ID;

-      your email address;

-      your game recordings/screenshots;

-      your device information;

-      your name/surname;

-      your date of birth;

-      games you played previously;

-      your IP address;

-      your country of residence;

-      your game usage data;

-      your operating system, performance & network data, error reports and logs;

-      your marketplace transactions (player trading), preferences/settings data, economy & reward data;

-      your survey feedback data; and

-      other information about you that will help us make a selection (collectively, the “Related Personal Data”).

This notice applies towards individuals who wish to be considered for the participation in our upcoming Pioneers Program, selection to the Pioneers Program as players and being contacted in case of selection (referred to as “you”).

*How will we use the Related Personal Data?

We will process the Related Personal Data to consider the potential players for the selection to the Pioneers Program and contacting them in case of selection. This implies using the Related Personal Data consistent with the goal of the Pioneers Program, including for the Pioneers Program selection.

We will also process the Related Personal Data to:

-      contact the players about the OTG game news, updates, and surveys – in case you give us consent to do so;

-      analysethe OTG game data and feedback to improve the OTG game or our service;

-      support the players in case of issues or questions;

-       protect the Pioneers Program from unlawful usage.

*What is the legal basis Gunzilla relies on?

We process the Related Personal Data for:

-      considering the potential players for the selection to the Pioneers Program and contacting them in case of selection – based on our legitimate interests to conduct the Pioneers Program and select players eligible for the Pioneers Program (GDPR Art. 6.1.f);

-      contacting the players about the OTG game news, updates, and surveys – based on your consent you have given to us (GDPR Art. 6.1.a);

-      giving the players access to the Pioneers Program – based on our performance of a contract between you and us, including https://gameoffthegrid.com/terms-console/ (GDPR Art. 6.1.b);

-      analysis of the OTG game data and feedback to improve the OTG game or our service – based on our legitimate interests to improve our services (GDPR Art. 6.1.f);

-      putting a watermark with your User ID on the Pioneers Program materials made available by us to you – based on our legitimate interests to protect the Pioneers Program from unlawful usage (GDPR Art. 6.1.f);

-       support the players in case of issues or questions – based on our performance of a contract between you and us, including https://gameoffthegrid.com/terms-console/ (GDPR Art. 6.1.b).

Your provision of the Related Personal Data is on a voluntary basis, however, you still may object against our use of the Related Personal Data by submitting a request to [email protected]. We will assess if we have compelling interests in continuing processing your Related Personal Data and stop processing those as soon as we can.

*How long do we store the Related Personal Data?

We will store your account related and preference data for the lifetime of your account.

The Pioneers Program specific data will be stored between 6 months and 1 year.

*Will we share the Related Personal Data with any third parties?

We may share your Related Personal Data with the third-party service providers which provide us with the following services: communications, player support, accounts, feedback, data analysis, game servers, email marketing, etc.

*Do we process children’s personal data?

Pioneers Program is not intended for use by anyone under the age of 18. We do not knowingly collect information from players under the age of 18 and discourage the use of Pioneers Program by children.

*US residents privacy notice

This US residents privacy notice is for individuals residing in the following US states: California, Colorado, Connecticut, Virginia, and Utah. It supplements the information contained in our main privacy notice. 

We collect, use, and disclose your personal information in accordance with the California Consumer Privacy Act of 2018, California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act.

If you are a resident of one of the above US states, we process the categories of your personal data specified in our main privacy notice. The purposes for processing your personal data are described in our main privacy notice. The sources from which your personal information is collected comprise the information provided by you to us and the information generated by us based on your use of Pioneers Program. We do not sell your personal information to anyone and we do not share it except as described herein. We may disclose all of the categories of personal data described above to the categories of third parties described in our main privacy notice.

As a resident of California you have the rights to:

-         know, at or before the point of collection, the categories of personal information collected by us, the purposes for which such information is collected or used, and whether such information is sold or shared, as well as information regarding the length of time we intend to retain each category of personal information;

-         request deletion of any personal information about you that we have collected from you;

-         request correction of inaccurate personal information;

-         request disclosure of information collected, including specific pieces of personal information we have collected about you;

-         request disclosure of information sold or shared;

-         opt-out of the sale or sharing of your personal information; and

-         nondiscrimination relating to exercise of your rights under the CPRA.

Depending on where you live and subject to certain exceptions, some or all of the following rights regarding your personal information may be available to you: right to know, right to correct, right to delete, and right to object to targeted advertising. To exercise any of your rights specified above, please submit a verifiable consumer request by emailing us at [email protected].

*Where can you get more information about processing?

Please review our https://gameoffthegrid.com/privacy-notice-web-console to learn more about our privacy practices, your rights, and Gunzilla contact details.