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PRIVACY AND COOKIE POLICY

Last updated: 14 May 2018

We, Pegnio Ltd, are committed to protecting your privacy and personal information. This Privacy and Cookie Policy (Privacy Policy) details the steps we take to protect your personal information when you visit https://www.cosmosinvictus.com (our game site), https://forums.cosmosinvictus.com  (our forums site) and/or use our game ‘Cosmos Invictus’ (which includes all content within or used in connection with ‘Cosmos Invictus’ such as card packs and in-game virtual items) (our game). Our game site, forums site and game are together our services. This Privacy Policy describes the personal information that we collect when you use our services, the purposes for which we use such information, and your choices regarding our use of it.

Our legal status under UK data protection law is that of a data controller and in this capacity we will securely store and process your personal information which you have provided to us. Data controller is a legal term which identifies the person who controls what to do with any given personal information.  As data controller we have registered with the Information Commissioner’s Office and our registration number is ZA281364.

The steps we take to protect your personal information and how you can review and correct your personal information are also covered here.

Changes to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will revise the “last updated” date at the top of the Privacy Policy.  Please ensure that you frequently check this Privacy Policy for any updates.

Collection of information

• This Privacy Policy applies in respect of all personal information you provide to us and your use of our services.

• The personal information we collect from you may include:

• any information you provide to us if you contact us;

• information you submit when you register for our forums site, which may include:

• your name;

• email address;

• password;

• forum display name; and

• in-game character name and ID

• other names/aliases used by you in our game, site or forums site;

information we receive from the gaming platform that you register with in order to download and play our game (which includes Steam), which may include:

• your gaming platform gaming ID

• your gaming platform user ID.

You are not required to provide any of this information, but if you do not, we may not be able to provide you with the requested services.

We may also observe your use of our services and derive certain information from this which may include personal data.

How is your personal information used?

• We will use the personal information you provide to us to:

• provide you with personalised visits to our game, game site and forums site;

• provide you with personalised game offers which may be of interest to you (where you have consented to be contacted for such purposes);

• provide you with services which you have signed up for;

• develop our game and detect any attempted cheating in respect of our game rules;

• develop our services to enhance their usability and functionality and improve the user-experience; and

• contact you from time-to-time.

With whom is your personal information shared?

We may share any information that we receive through our services with service providers retained in connection with the provision of the service, including for data analytics purposes.  One of the service providers that we use for data analytics is Google Analytics. If you do not want Google Analytics to collect and use information about your use of our services, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).

We may disclose depersonalised data (such as aggregated statistics) about the users of our services in order to describe our sales, customers, traffic patterns and other services information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

We may occasionally be required by law, court order or governmental authority to disclose certain types of personal information.  Examples of the type of situation where this would occur would be:

• in the administration of justice; or

• where we have to defend ourselves legally.

Finally, in the event of a reorganisation, sale or takeover we may need to disclose personal information to the potential acquirer and its advisers, though we will do so on the basis that the information is kept in confidence and, if the acquisition, sale or takeover takes place, used only in accordance with applicable law and this Privacy Policy.

The requirements of data protection laws

We regard the lawful and correct treatment of your personal information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal information lawfully and correctly. To this end we fully endorse and adhere to the data protection principles set out in data protection legislation. In particular, without your consent or first amending this Privacy Policy to reflect any change in our usage of personal information:

• we will not use your personal information for any purpose that is incompatible with this Privacy Policy;

• we will only collect sufficient personal information for the uses set out above;

• we will endeavour to keep your personal information up-to-date;

• we will operate appropriate technical and organisational processes to protect your personal information against unauthorised or unlawful access or processing and against accidental loss or destruction. The measures we take are described elsewhere in this Privacy Policy; and

• we will not transfer your personal information to a country outside the European Economic Area unless safeguards are in place to protect your personal information to the standards that apply within the EEA.

Use of cookies and web beacons

Cookies are small files that websites save to your hard disk or to your browser’s memory.  The cookies used on our services are listed below.

You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of our services or other websites that you visit.

To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s websites here.  Furthermore, whilst we do not use third party marketing cookies, you can learn more about these and how to delete them here.

By using our services you consent to us using the following cookies:

Cookie Purpose More Information

  • “PHPSESSID” is used by the website to keep a session active for visitors.
  • “_ga, “_gat” and “_gid” are cookies used by Google Analytics to provide visitor information.

Security

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure.

For example, we store the personal information you provide on computer systems with limited physical and network access that are located in facilities to which access is limited. Only authorised personnel are allowed to access personal data.

It is your responsibility to ensure the security of your password that you use on our forums site and not to reveal this information to others.

Retention

We will hold your personal data for so long as we are providing services to you and for no more than 3 years after.  We will endeavor to delete any personal data sooner where it is not necessary for us to hold this, but please be aware that we may hold personal data for longer if we are under a legal obligation to do so or where we have a reasonable belief that it is necessary to do so for business or legal reasons.   

Your rights

You have the following rights in relation to your personal data:

• a right of access to a copy of the information comprised in your personal data;

• a right to access your personal data in machine-readable format and to request that we transfer this to a third party data controller;

• a right to object to processing that is likely to cause or is causing damage or distress;

• a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed;

• a right to claim compensation for damages caused by a breach of data protection legislation; and

• a right to lodge a complaint to the Information Commissioner’s Office in respect of our use of your personal data.   

If you are unsure about your rights or are concerned about how your personal data may be processed you should contact the Information Commission’s Office. 

If you contact us in relation to your rights we will do our best to accommodate your request or objection.  Please note, however, that not all rights are absolute.  Sometimes other legal obligations or third party rights will take precedence.

If you request a copy of personal data that we hold about you, we may require ID and we may charge a fee of £10 to meet our costs in complying with this request. 

You can help us to maintain the accuracy of your information by notifying us of any change.

Please email us (support@pegnio.com) f you would have any queries about, or would like to enforce, your rights set out above.

Children’s information

Our service is not aimed at children and we do not knowingly collect personal information from children under the age of 12. If we find out that a child under 12 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 12 has given us personal information, please contact us as set out under “Contact us” below.

Links to other websites

Our services may contain links to other websites and our game can be downloaded and played via third party game platforms such as Steam. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and game platforms. We encourage you to carefully review these sites’ privacy policies so that you know how they will collect, use, and share your information.

Contact us

If you have questions regarding this policy or our handling of your personal information, please contact us via email at: support@pegnio.com . We will promptly address your concern and strive to reach a satisfactory resolution.