MAXKO Privacy Policy

MAXKO respects the privacy of its players and recognizes the importance of providing a secure environment for their data. We have adopted this Privacy Policy that explains how and why we collect, store and use the information you provide us.

Who is processing your data?

MAXKO Limited Liability Company, is the data controller for the processing of your personal data. We are a registered company located at

Skradinska 2, 44000 Sisak, Croatia

Contact information for the Data Protection Officer for both of these companies is located in the last section of this document.

What information do we collect, and how long do we keep it?

We collect information from or about you in the following ways:

Information provided by you. Information provided by you when you create or update your account(s); while you use our social features and channels to communicate with others; when you use any of our services for purchases or financial transactions such as store purchases, in-game purchases, and/or prize processing; and while you are receiving customer service support.


Information we get or generate from your use of our games or services. We collect data related to: your game play and in-game activity, the services that you use and how you use them, and your devices and activities when you install or access our services.

Information collected from external sources. We may receive information about you and your activities from third parties when you link to external accounts (such as Facebook, PlayStation, XBOX or Twitch) and from advertisers or service providers about your experiences or interactions with them. We might also obtain information from public sites on the internet, such as Twitch, Instagram and YouTube, to mention a few. For example, if you login to a site or app using Facebook Connect you may be asked if you wish to share information from your Facebook account with us. If you participate in a game or other feature where your score is posted on social media content, or if you use a "like" or a "share" button for a feature on our sites or apps, then the third party may share information with us.

We treat all information associated with your account as personal information. MAXKO collects the following categories of data depending on which product(s) or service(s) you are interested in or interacting with. We usually retain data for only as long as necessary to provide you with products, services and an immersive entertainment experience. Exceptions are noted below.

ACCOUNT DATA

Player Account Data refers to information that is provided and generated when a player creates his or her account. Most of this data is available to the player by logging into his or her account and can be updated by the player in the account settings section.


Examples:
Account name, email address, security code, date of birth, home address, shipping address (on file), account balance.


Who has access to this type of data?
Operations, Game Teams, Customer Service, Publishing and Security.

CUSTOMER SERVICE

We also use the information we collect while assisting players through our customer support services to investigate and address players’ concerns and monitor and improve our services. Information gathered or produced during support of our players is retained for up to 2 years to ensure that we address concerns and issues in the best way possible.


Examples:
Issues raised, case history, restrictions history, contact details, customer service communications, account notes.


Who has access to this type of data?
Most of the time, it’s just Customer Service and Security, but occasionally Operations, Game Teams and Legal access this data.

SOCIAL DATA

MAXKO uses the information we collect from players’ actions to enable communications between our players in multiple ways, such as chat, Forums and on-line gaming.


Examples:
Forum content (version, allocation, locale, time zone, access groups, game accounts, posts, chat groups, chat logs, friend lists, profile information).


Who has access to this type of data?
Operations, Customer Service, Game Teams, Publishing and Security.

TRANSACTIONS

We collect transaction details related to the licensing and purchasing of our products and services, and also the contests and competitions we sponsor. Transaction data may be retained for up to 7 years (primarily for audit purposes).


Examples:
Order details/history, subscriptions, chargebacks, refunds, gifts, payment detail, shipping details, prize awards and competition accreditation details.


Who has access to this type of data?
Operations, Consumer Products (as applicable), Customer Service, Publishing and Security.

ACTIVITY DATA

When a player interacts with our services, we collect server logs. In most cases, server logs are retained between 90 days and 1 year.


Examples:
IP address, access dates and times, activity region and activity logs.


Who has access to this type of data?
Operations, Game Teams, Customer Service and Security.

DEVICE DATA

We may collect information about the devices used to access our services.


Examples:
Hardware models, operating systems and versions, unique device identifiers.

Who has access to this type of data?
Operations, Game Teams and Security.

COMMUNICATIONS

MAXKO may use the information we collect from players or partners to communicate with our players about our current and upcoming products, services, promotions, studies, surveys, news, updates and events. MAXKO may also use this information to promote and process contests and sweepstakes, fulfill any related awards and serve you relevant ads and content about our services. Data gathered for a specific occurrence such as surveys and giveaways are hold no longer than 90 days.


Examples:
Name, email address, survey details, purchase/license history, activity history, email activity, Facebook and Twitter handles.


Who has access to this type of data?
Operations and Publishing.

LEGAL RECORDS

We keep records as support for any actual or anticipated legal matter for up to 7 years.


Examples:
Pro-Players' contract agreements, case files.

Who has access to this type of data?
Operations and Security.

GAME DATA

Game data are generated while a player plays our games. We keep records of players’ game licenses, progress, history, stats, in-game purchases and interactions with other players.


Who has access to this type of data?
Operations, Game Teams, Customer Service, Publishing and Security.

MEDIA INFORMATION

Contact information for journalists and players that have an impact on our community.


Examples:
Discord handle, Reddit handle, Twitch cheer, Twitch handle, Twitter handle.


Who has access to this type of data?
Operations, Esports and Publishing.

Why do we process your data?

MAXKO collects and uses your data for the following purposes:

Gameplay Experience. Creating the well-designed, highly enjoyable entertainment experiences you can find within our epic games! This includes:

Progress and History

  • Examples of data used:
    • GAME DATA: Game stats, match history, quest in progress, etc.

In-game Social

  • Examples of data used:
    • GAME DATA: Guild information, friends list, etc.

Unlocks

  • Examples of data used:
    • GAME DATA: Inventory items: gold, dust, armory, skills, etc.

Game Currency

  • Examples of data used:
    • GAME DATA: Earnings history, items a player can/has purchase(d): portraits, skins, heroes, etc.

Player’s Account, Parental Controls and Security. Players of most of our games use a MAXKO account to house assets, communicate with friends and learn about our games and services. Parents of our younger players may set parental controls to monitor and control their children’s gaming. This includes:

Player's Account

  • Examples of data used:
    • ACCOUNT DATA: Name, email address, age
    • ACTIVITY DATA: IP address, login information Parental Control
  • Examples of data used:
    • ACCOUNT DATA: Parental control email, child’s account information

Business optimization and service development. We conduct troubleshooting, research, analysis and product and service development to provide you with the best gameplay experiences and services. This includes:

Analytics & Data Segmentation

  • Examples of data used:
    • ACCOUNT DATA: MAXKO account, country, third parties’ IDs
    • ACTIVITY DATA: IP address
    • GAME DATA: Related players, chat records

Training & Development

  • Examples of data used:
    • ACCOUNT DATA: Name, phone number, country, home address
    • ACTIVITY DATA: IP address
    • GAME DATA: Character name
    • CUSTOMER SERVICE: Ticket issue description, account notes, Customer Service chat log

Reporting

  • Examples of data used:
    • ACCOUNT DATA: Account region
    • ACTIVITY DATA: IP address, preferred language

Global Customer Service. We provide you with personalized support to investigate and address any possible difficulty you might experience with our games, your account or your purchases. This includes:

Customer Service

  • Examples of data used:
    • ACCOUNT DATA: country, language
    • ACTIVITY DATA: IP address, region, timestamp
    • GAME DATA: Game account, guild name, character name
    • CUSTOMER SERVICE: Chat records, case history

Forum Moderation

  • Examples of data used:
    • SOCIAL DATA: Forum posts

Business Operations. We process orders for our products, tournaments and services. This includes:

Store Purchase

  • Examples of data used:
    • ACCOUNT DATA: Email address, country, language, home address
    • ACTIVITY DATA: IP address
    • TRANSACTIONS: Invoices, refund details, subscriptions, licenses, payment details

Communications with our players. We communicate with our players about products, services, promotions, studies, surveys, news, updates and events. MAXKO may also use the information to promote and process contests and sweepstakes, fulfill any related awards and serve you relevant ads and content about our products and games.

Specifically, we use your data for the following Publishing purposes:

Surveys

  • Examples of data used:
    • COMMUNICATIONS: Age, country, gender, IP address

Mobile Push Notifications

  • Example of data used:
    • DEVICE DATA: Phone Device Token

Analytics & Data Segmentation

  • Examples of data used:
    • ACCOUNT DATA: Such as: country, state, postcode or city of residence
    • GAME DATA: Related players
    • DEVICE DATA: Device ID
    • ACTIVITY DATA: IP address

Ad Targeting via “Paid Media” and “Custom Audience” (Your unencrypted personal data are never shared with third parties without your consent.)

  • Examples of data used:
    • ACCOUNT DATA: Such as: name, country, state, postcode or city of residence, email address, account region

Transactional and Publishing Campaigns and Promotions

  • Examples of data used:
    • ACCOUNT DATA: name country, state, postcode or city of residence, email address, account region

Unethical Behavior Prevention. One of our core values is: Play Nice; Play Fair. We devote resources to minimize fraud, cheating and abusive behavior. This includes:

Abuse and Cheat Detention

  • Examples of data used:
    • ACCOUNT DATA: Account name, country
    • ACTIVITY DATA: IP address, region
    • DEVICE DATA: Device ID
    • SOCIAL DATA: Related players
    • GAME DATA: Chat records

Account Compromise Prevention

  • Examples of data used:
    • ACCOUNT DATA: Account name, country, date of birth, external account IDs
    • ACTIVITY DATA: IP address
    • DEVICE DATA: Device ID
    • TRANSACTIONS: Payment method

Account Restrictions and Penalties

  • Examples of data used:
    • ACCOUNT DATA: Account name
    • ACTIVITY DATA: Region
    • CUSTOMER SERVICE: Account restrictions history, penalty history, chat records

Legal proceedings and requirements. We may use the information we collect to investigate or address claims or disputes relating to your use of MAXKO’s services or as otherwise allowed or required by applicable law. This includes:

Litigation or Pre-litigation

  • Examples of data used:
    • ACCOUNT DATA: Name, home address
    • CUSTOMER SERVICE: Account notes
    • LEGAL DATA: Case file

Security Monitoring and Investigations

  • Examples of data used:
    • ACCOUNT DATA: Age, name, address, email address, country
    • ACTIVITY DATA: IP address
    • DEVICE DATA: Device ID
    • SOCIAL DATA: Related players
    • GAME DATA: Chat records

Legal Compliance

  • Examples of data used:
    • ACCOUNT DATA: Age, name

We process the above in accordance with the legal bases determined as follows:

  1. Necessary for the performance of your game contract or any other feature you request or enable. These are required, and ceasing their processing will remove access to certain features or to the game service altogether. This includes using information for:

    • Abuse and Cheat Detention and Sanctions
    • Account functionality
    • Account Compromise Prevention
    • Chat Applications
    • Contest Participation
    • Global Customer Service
    • Forums
    • Game functionality
    • Parental Control
    • Enrolled promotions/contests
    • Purchases

  2. Consent. You can withdraw your consent to these at any time.

    Consent functionality during account creation

    • Receive news and exclusive offers about selected third-party products and services – Carefully selected news, event information and special offers about third-party products and services

    Consent functionality in account management – Communications Preferences

    • Receive news and special offers from MAXKO by email – Carefully selected news, event information and special offers about MAXKO products and services
    • Receive news and special offers about selected third-party products and services by email – Carefully selected news, event information and special offers about third-party products and services * Have MAXKO offers recommended to me on partner sites based on data MAXKO collects – Communications personalized to your experience with MAXKO

    Consent obtained in other instances

    • Cookies and Tracking Technology - Information stored on your device (cookies and similar tracking technology), so that we can better understand how our sites and apps are used and send more relevant offers to you. See the Tracking Technology section below regarding how to withdraw this consent.

  3. Legitimate interest. We use your data for purposes that are not harmful to your privacy and that can be reasonably expected within the context of your relationship with MAXKO. This includes using information for:

    • Ad Targeting via ‘Paid Media’
    • Ad Targeting via ‘Custom Audience’ and similar systems—Appropriate ads for players considering their previous purchases (Your unencrypted personal data are never shared with third parties without your consent.)
    • Analytics & Data Segmentation
    • Business Optimization and Service Development
    • Publishing Email - Marketing Campaigns
    • Research Groups
    • Customer Support

  4. Legal obligation. We process your data due to a legal obligation or right. This includes using information for:

    • Legal Compliance
    • Litigation or Pre-litigation
    • Security Monitoring and Investigations

With whom may we share your data?

MAXKO websites have message boards, forums, and/or chat areas, where users can exchange ideas and communicate with one another. When posting to a message board, forum, or chat area, please be aware that the information is being made publicly available on-line and the user does so at his or her own risk. For certain forums, anyone posting or replying to a post may be doing so using the option to display the name of their primary in-game character.

Some of MAXKO’s products, services and features require that we share information with other users, our partners and service providers, or for legal reasons or in the event of a dispute.

  1. * With partners and service providers. MAXKO may provide information to its vendors, consultants, marketing partners, research firms and other service providers or business partners. For example, we may provide information to such parties to help facilitate event ticket sales, conduct surveys on our behalf and process payments for our products and/or games.

  2. * With other players and/or the general public. Information may be viewable by your friends, people in games, or the public in general if you play our games, use certain features in our games, use certain features on our platforms (such as chat applications in game) or make posts in the forums.

  3. * For legal reasons or in the event of a dispute. MAXKO may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request. This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Service, user agreements or other policies to protect MAXKO’s rights or property or the rights or property of others, or in the event of a claim or dispute relating to your use of our services.

International Transfer

Your personal data will be transferred to and processed in the [Croatia] where many of our central databases operate. We use European Commission approved contract clauses to protect your personal data. Where we share data with vendors, we use these clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules to protect your data. A copy of the relevant mechanism can be provided for your review on request to our Data Protection Officer using the details set out below.

What rights do I have?

Access my data:

You may be able to receive a report about the data MAXKO stores about you. To learn more about accessing your data, please contact us.


Erasure:

You may have a right to request the deletion of some your data. MAXKO is required by law to retain certain data. To learn more about having your data erased or anonymized, please contact us.


Object:

You may object to the processing of your data if you believe MAXKO doesn’t have the appropriate rights to engage in that processing or if you wish to ask MAXKO not to process your personal data for direct marketing purposes. To learn more about making an objection, please contact us.


Rectification:

You can correct your personal data if you feel it’s inaccurate. Please log in to your MAXKO account and use the account management settings to make the changes.


Restrict Processing:

You can request that your data no longer be processed in certain cases, for instance, when you exercise your right to object as described above. When objecting, you will be given an option to restrict processing.

What are tracking technologies, and how are they used?

MAXKO and our partners, such as marketing partners, may use tracking technologies like cookies, beacons, tags, scripts and unique codes used in apps. These technologies are used in analyzing trends, administering the websites or apps, tracking users’ movements around the websites or apps and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual, as well as an aggregated, basis.

We use this technology for various purposes, including our shopping cart, maintenance of user settings (e.g. language preference) and authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our websites, but your ability to use some of the features or areas of our websites may be limited.

We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For this reason, these types of clear gifs are tied to personal data.

We, and third parties with whom we partner to provide certain features on our websites or to display advertising based on your web browsing activity, use Local Shared Objects such as Flash cookies and Local Storage such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here.

We partner with third party ad networks to either display advertising on our websites or to manage our advertising on other sites. Our ad network partners may use tracking technologies to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. Some of these ad networks are members of the Networking Advertising Initiative (“NAI”) and/or the Digital Advertising Alliance (“DAA”) – organizations who offer a single location to opt out of receiving tailored ads. If you wish not to have your information used for the purpose of serving you targeted ads, you may opt-out by visiting the DAA's Consumer Choice page and/or the NAI’s Consumer Opt-Out page. Please note this does not opt you out of being served advertising. You will continue to receive generic, or non-targeted, ads. Please also note that we strive to adhere to the DAA's Self-Regulatory Principles for Online Behavioral Advertising.

What are Internet Protocol addresses?

An Internet Protocol ("IP") address is the unique number assigned to your computer. MAXKO may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused. See tracking technology discussion above.

What level of security is applied to your personal information?

To help protect the privacy of the data and personally identifiable information you provide to us and that we learn from you, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of personal information. We restrict access to your personal data to those employees indicated above. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.

Note to Parents

We recognize a special obligation to protect personal information about children. We urge parents to instruct their children to never give out their real names, addresses or phone numbers without permission when they are on-line.

Once a child states that his/her age is under 12, he or she will be unable to register an account with us. We do not knowingly collect or store any personally identifiable information from children under the age of 12. If parents believe that we have unintentionally collected their children’s personal information, they may request the deletion of the information by contacting us at privacy@asteidus.com.

MAXKO has engineered Parental Controls to help parents monitor and limit, if necessary, the amount of time their children spend interacting with our games.

Further Information or Complaints

If you have questions or concerns regarding data protection at MAXKO, you may contact our Data Protection Officer by writing to privacy@asteidus.com.

Each EU Member State shall provide one or more independent public authority (ies) to be responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the Union (‘supervisory authority’). If you feel that MAXKO has violated your rights, or if you wish to raise a concern with the data protection authorities, please contact the supervisory authority in the country where you live, work, or where you believe a breach of data protection law has occurred.

MAXKO Privacy Policy: Greater European Region, updated May 2019.