For more information, see Cookies.
More information about the Terms of Service and Privacy can be found at
http://www.google.com/analytics/terms/en.html or at
https://www.google.com/intl/en_uk/policies/.
Facebook Plugins
Black Tower Games LTD uses social media plugins. For example, the "Like" button from the social networking site
facebook.com. These plugins are operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). The plugins can be identified by one of the Facebook logos.
When an user accesses one of our web pages containing one of these plugins, the internet browser connects directly to the Facebook servers. Facebook sends the contents of the plugins directly to the user's browser and back.
If you have activated scripts in your browser and have not installed a script blocker, your browser will forward your Personal Data to Facebook without any separate request. If logged-in, an immediate assignment of the data to the Facebook profile is possible. Since we have absolutely no control over the amount of data that Facebook collects with the help of these plugins, we would like to inform the user about our current level of knowledge:
The plugins that are integrated mean that Facebook will be notified when the user has accessed the corresponding page on our website. If the user is logged in to Facebook at the same time, Facebook can assign a visit to the user's personal Facebook account. When the user interacts with the plugins, for example by clicking on the "Like" button or posting a comment, the information is immediately transmitted by the browser directly to Facebook, where it is stored. If the user does not use Facebook, the service can still capture and store the IP address. For more information on how much data is collected and why and how it is then processed and used by Facebook, as well as information about user rights and the settings that are available to protect the privacy of users, you can access the Facebook Privacy Policy
www.facebook.com/policy.php.
If you do not want Facebook to collect data from the Black Tower Games LTD website and link it to the information stored on Facebook, please log out of your Facebook account before visiting our websites and block the execution of Facebook script content in your browser.
If you are not logged in to Facebook or have not (yet) agreed to your data being collected and used, you should not click on Facebook plug-ins.
Facebook Pixels
Black Tower Games LTD also uses Facebook Pixels. The Facebook Pixel is part of the code implemented in our website. Its goal is to show conversions (it shows which devices were used by a user in an action) to create a so-called lookalike audience (ie, to reach users with advertisements that have features similar to other customers and to generate comprehensive statistics on the use of our website.
When you visit our website, the Facebook Pixel creates a direct link to the Facebook servers. In this case, the Facebook server will be informed that you have visited our website and Facebook will assign this information to your personal Facebook profile. This process is designed to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and may help to optimize future advertising efforts.
Our legitimate interest in data processing also lies in these purposes.
The data collected is anonymous to us, so do not provide us with any conclusions about the identity of the users.
For more information see Cookies.
Further information about the collection and use of your personal data via Facebook as well as your rights and options can be found here:
https://www.facebook.com/about/privacy/. How to disable the feature is explained here:
https://de-de.facebook.com/business/help/1415256572060999?helpref=uf_permalink. For this you must be logged in with your Facebook account.
Facebook Insight
When you visit our Facebook pages, Facebook save Cookies on your device. The data collected includes the age group, gender, education, occupation, relationship status and other information that is publicly available on your Facebook profile. This serves Facebook and us to find out more about your interests and hobbies and to make you more suitable offers. This is also our legitimate interest.
We point out that Facebook currently does not offer the operators of a fan page any possibility to control or to restrict the Facebook Insight cookie. If you do not agree, we ask you not to visit our fan page. You also can deactivate the use of Cookies in your browser settings at any time and delete already stored Cookies.
For more information see Cookies.
Twitter conversion Tracking
We use Twitter Inc.'s Conversion Tracking Service, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter"). This tracking records when a user of our website clicks on a link posted by Twitter. In this way, we and Twitter can see if a login has taken place. The identity of the user remains anonymous. In addition, we use the Tailored Audiences Service from Twitter. This allows us to approach our website users with targeted ads. To do this, Twitter uses a code snippet (tag) that we have integrated into our website. During this process, no personal data will be collected. Tailored Audiences is also used to create meaningful target lists.
This is also our legitimate interest in processing your data.
For more information about the privacy policies of Twitter, see their privacy policy (
https://twitter.com/privacy?lang=en).
You can customize your privacy settings for custom ads at this link:
https://support.twitter.com/articles/20170405-your-privacy-controls-for-tailored-adsTwitter also supports "Do not Track" (DNT). If you have activated this option in your browser, Twitter will not receive browser-related information (browser cookie ID) from web partners with which it can tailor ads for you.
Mobile Tracking Technologies In our mobile apps we use so-called mobile tracking technologies. We use these services to collect data about the use of our apps so we can constantly improve our offerings. When using our apps, the data you submit will be collected and analyzed.
In this regard, the following data is compiled: IP address that is immediately anonymized, MAC address, anonymized device ID (identifier for advertisers – IDFA or Google Advertiser ID – GAID), browser type, language settings, ISP, network status, time zone , URL of entry and exit pages, date of access and time, clickstream data and other statistical information about the use of our services.
A direct individual identification based on this data is not possible. The data collected in this way is used to create anonymous user profiles. The data collected by the tracking technologies will not be used to personally identify a visitor to our web pages without his express consent. The capture and storage of the data can be disabled at any time with future effect by adjusting your mobile device's settings as follows:
If it's an Apple mobile device (IFDA): Open your mobile device settings (such as iPhone or iPad) and select the "Privacy" menu item. Under "Advertising," you can turn off ad tracking.
For Android devices: Open the settings in your app list and tap the "Show" button. If the ad window is open, you can disable the Google Advertising ID.
You can also reset your IFDA or Google Ad ID or assign a new one in the settings.
Your Legal Rights You can revoke a given consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.
You can also request information from us at any time as to which Personal Data we process from you (Right of Access, Art. 15 GDPR). Insofar as the data concerning you is incorrect or incomplete, you have a Right of Rectification (Art. 16 GDPR). In certain cases, you have the right to request a restriction of processing. Details can be found in Art. 18 para. 1 DSGVO.
You can demand that the Personal Data concerning you shall be deleted immediately (Right to Erasure, Art. 17 GDPR). In particular, we are required to immediately erase this information if the data is no longer necessary for the purposes for which it was collected or if you revoke your consent. Further deletion obligations can be found in Art. 17 para. 1 DSGVO.
Please note, however, that statutory provisions provide for a retention period and we are allowed to store data for the settlement of disputes, for the enforcement of our Terms of Use and due to technical and legal reasons (e.g. backup files). This data may only be deleted after periods of time specified by law.
If you have the right to rectify, delete or restrict the processing by us, we are obliged to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort (Notification Obligation, Art. 19 GDPR). You also have the right at any time, for reasons arising from your particular situation, to prevent and object the processing of your Personal Data, pursuant to Art. 6 para. 1 lit. e or f DSGVO.
You also have the right to receive personally identifiable information you provide to us in a structured, common and machine-readable format. You also have the right to transfer this data to another person without hindrance (Right to Data Portability, Art. 20 GDPR).
Without prejudice to any other administrative or judicial remedy, you have the right to file a complain to a supervisory authority, in particular in the Member State of residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is violates the GDPR.
Please direct your data protection request to the data protection officer of Black Tower Games LTD.
B. Non-personal information collected by Black Tower Games LTD
Non-personal data cannot be used to identify or contact you. Black Tower Games LTD collects non-personal data about your use of our online, off-line and mobile games and services both on our website and in the course of game play and software usage (on PC, mobile and console platforms).
Black Tower Games LTD may collect certain non-personal data including gender, zip code, information about your computer, hardware, software, such as your hardware settings and components, platform, media, browser information, including your browser type and the language you prefer, referring and exit pages, including landing pages and pages viewed and used devices including device event information, including crash reports, request and referral URL's and system activity details (e.g. whether you encountered an error playing our games or lost internet access). We also collect other Non-personal data such as feature usage, game play statistics and scores, user rankings and click paths as well as other data that you may provide in surveys, via your account preferences and online profiles or through purchases, for instance. We may also receive either non-personal or public information from third parties in connection with market and demographic studies that we use to supplement personal data provided directly by you.
We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.
In addition to personal information, Black Tower Games LTD collects, among other things, non-personal information when you actively enter it into various online, offline or mobile activities, including online and mobile purchases, game registration and marketing surveys.
2. SECURITY OF DATA
We commit ourselves to data security within the framework of the applicable data protection laws. Your Personal Data is protected against unauthorized access and loss through the use of various electronic, technical, physical, administrative and contractual measures. Black Tower Games LTD has taken the necessary technical and organizational precautions to ensure that the privacy policy is adhered to both internally and by external service providers.
We adhere to generally accepted industry standards to protect the personal information we provide in both transmission and storage.
All Black Tower Games LTD employees are required to comply with data security and privacy practices, and have appropriate instructions and are trained on a regular basis.
For payment transactions, your data is encrypted using the SSL process. Our employees are not authorized to request further user data such as bank details or passwords.
Persons requiring access for technical, business, or editorial maintenance of the server and portal are legally bound by a confidentiality and non-disclosure agreement
Please note, however, that no electronic communication or electronic storage method is completely secure. We remind you that despite our high standards, information that you voluntarily provide on the Web is never guaranteed to be 100% secure. There is always the danger that third parties will gain unauthorized access. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee absolute security. Black Tower Games LTD is not responsible or liable for the disclosure of data due to data transmission errors or unauthorized access by third parties.
3. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
General
Your personal information is shared globally with companies of the Black Tower Games LTD (to affiliates, affiliates and the parent company). Due to the corporate structure, all companies of the Black Tower Games LTD have a legitimate interest in the transfer pursuant to Art. 6 para. 1 lit. f DSGVO. From time to time, Black Tower Games LTD employs third party contractors to collect personal data on our behalf to provide email delivery, product, or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites. Black Tower Games LTD will only pass your personal and/or billing-related data to third parties, external service providers and investigative authorities as far as this is required to fulfil the agreement. We ask some third party contractors, such as credit agencies or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors' needs and preferences. When our third party contractors collect and/or have access to the personal information you provide to Black Tower Games LTD, Black Tower Games LTD requires that they adhere to our stated privacy policies and protect the confidentiality of personal information they collect or have access to in the course of their engagement. These third parties are prohibited from using your personal data for any other purpose without your specific consent. Therefore, you may opt in to allow us to share your Personal Data with these companies and organizations that provide products or services that we believe may be of interest to you. To opt out of further communications from a marketing partner or sponsor with whom your information has been shared, please contact that partner or sponsor directly. In any case, you will be notified before your personal data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your data with that party.
Payment processing takes place via external service providers (e.g. credit card companies, banks, Paypal). Your protected interests are considered according to the legal provisions. External service providers are obliged to treat your data confidentially and securely and may only use your data as far as this is required to fulfil their duties. In the event of payment arrears, Black Tower Games LTD will, if necessary, instruct a collection company or a lawyer to collect the payable amount. The required data are passed for this purpose and utilized in compliance with our Privacy Policy.
In other cases, your personal information will only be disclosed to third parties with your express consent. However, we may share non-personally identifiable information (in a form that you do not personally identify) with third parties.
When Personal Data is transferred to agents / service providers under the terms of the contract, they are bound by applicable privacy laws and other legal regulations, as well as the Privacy Policy of Black Tower Games LTD.
Black Tower Games LTD may also disclose Personal Data to law enforcement agencies or the relevant civil authorities to enforce legal rights and to comply with the law, or to comply with a decision by a government agency or other competent authority, or if we have reason to believe that disclosure is required to respond to potential or actual violations or interference with our rights, property, reputation, business operations, users or others who may be harmed, or if we believe disclosures are required to protect our rights or us against fraud, or to comply with any Black Tower Games LTD lawsuit, court order or legal process served.
Data transmission to a country outside the European Economic Area (EEA)
Black Tower Games LTD is part of a global organization, and the computer systems on which we collect, store and use information are predominantly in the EEA. In certain circumstances, we may use data storage facilities outside the EEA (for example, in the US or Asia).
Your personal data will only be transferred to third countries if this is absolutely necessary for the fulfillment of the purpose of the contract or if you have explicitly consented to the transmission. When submitting your data to a third country, we comply in particular with Articles 44 – 49 GDPR.
More information can be found under the item Your Legal Rights.
4. REVOCATION / DELETION OF YOUR DATA
You have the right to correct or deleted data that you have entrusted with us at any time. Please send an e-mail to artemozolov@blacktower.vc to our data protection officer for requesting the deletion or correction of your account details. You can also make your inquiries by phone or post. We will gladly review, update or remove the information. We remind you that it is required to keep certain data for certain periods in order to settle disputes, enforce our User Agreement and technical and regulatory requirements. This data may only be deleted after periods of time specified by law.
Further information can be found under the point Your Legal Rights.
5. NON-LIABILITY FOR THIRD PARTIES
We remind you that in various technical areas we work with external partners who also offer websites and services accessible from our sites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third party site, including on an advertisement, you will leave the Black Tower Games LTD site and go to the site you selected. As we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as Black Tower Games LTD. These third party websites and services should have their own privacy policies. We assume no responsibility or liability for such declarations or activities that take place at other sites. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website you should consult that site's privacy policy before providing any personal information.
6. CHILDREN
Protecting the privacy of children is particularly important to us. Black Tower Games LTD understands that parents, guardians or other adults often use our family services, including for use by minors. If a child under the age of 16 (or below the minimum age in the Member State concerned, which can be lower) submits Personal Data to Black Tower Games LTD and we learn that such Personal Data contains information of a child below 16 (or below the minimum age in the area, which could be lower) and there is no effective consent, we will delete the data as soon as possible. It is our policy to comply with any applicable law protecting minors.
The consent of children under the age of 16 is only lawful if the parents have given their consent. Each member state of the EU can reduce the age to a maximum of 13.
Black Tower Games LTD, taking into account the available technology, makes efforts to make sure that the parents have given their consent to children. Nevertheless, we would like to make parents aware that age verifications can be technically bypassed. Please do not leave your children unattended on the Internet and explain their importance to the proper handling of their data.
7. MODIFICATION OF THE PRIVACY POLICY
Black Tower Games LTD reserve the right to modify and update this Privacy Policy at any time in accordance with applicable privacy laws. If we change our Privacy Policy, we will post those changes to this Privacy Policy, the website or other places so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material or significant changes to this Privacy Policy, we will notify you by email or by a notice on the applicable websites or during log in. Please visit this page frequently. Revisions to terms affecting existing Black Tower Games LTD services shall be effective thirty (30) days after posting. Your continued use of our websites, games, online and mobile products and services will signify your acceptance of the changes to our Privacy Policy.
8. THIRD PARTY PRODUCTS AND/OR SERVICES
Users may register for other services from our websites. Certain products and/or services available on our service are provided to you in partnership with third party(s) and may require you to disclose personally identifiable information in order to register for and access such products and/or services. Such products and/or services shall identify the third party partners at the point of registration. If you choose to register for such products and/or services your personally identifiable information will be transferred to such third parties and will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy practices and policies of such third parties and, therefore, you should review the privacy practices and policies of such third parties prior to providing your personally identifiable information in connection with such products and/or services.
9. QUESTIONS AND COMMENTS
If you have any questions, concerns or remarks about data privacy, please contact our data protection officer by email to artemozolov@blacktower.vc.