Privacy Policy

Reforged Studios Oy (“Reforged Studios”, “we”) is an online game service provider providing the website reforgedstudios.com as well as online games for natural persons through mobile applications available for download from App Store and Google Play (jointly the “Services”).

Our Privacy Policy explains, for example, the types of personal data we process concerning the users and visitors of the Services and the potential users of the Services. This Privacy Policy also explains how we process your personal data and how you may use your rights as a data subject (e.g. right to object, right of access).

In this Privacy Policy, the word “you” or “User” may refer to any of the aforementioned individuals. The word “Registered User” refers to the registered user of the Services.

Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.

This Privacy Policy may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on our website. It is also accessible through a link on the mobile applications provided by us. We will not make substantial changes to this Privacy Policy or reduce your rights under this Privacy Policy without providing a notice thereof.

1. CONTROLLER’S CONTACT DETAILS

Name: Reforged Studios Oy
Company ID: 2684306-5
Correspondence address: Lapinlahdenkatu 16, 00180 HELSINKI 

E-mail: contact@reforgedstudios.com
Phone: +1 (949) 482-2860
http://www.reforgedstudios.com

2. PERSONAL DATA PROCESSED AND SOURCES OF DATA

The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.

User Data

User Data is personal data collected directly from you or other Users of the Services. We may collect User Data from you in a variety of ways, including when you register to or use the Services or when you subscribe to a newsletter or communicate with us. Further, please note that we also collect details of any transactions and payments the Registered Users carry out through the Services.

User Data that is necessary in order to use the Services

The following personal data collected and processed by us is necessary in order for a proper performance of the contract between the Registered User and us as well as for the compliance with our legal obligations.

When the Registered User registers to the Services and creates a user account, the Registered User needs to provide us with the following information:

  • nickname

User Data you give us voluntarily

We may also collect and process the following User Data provided voluntarily: 

  • your marketing opt-ins and opt-outs
  • information you provide in correspondence with us. 

Analytics Data

Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.

We may automatically collect the following Analytics Data when you visit or interact with the Services:

  • Device Information. We collect the following information relating to the technical device you use when using the Services:
    • device and device identification number, device IMEI
    • country
    • IP address
    • browser type and version
    • operating system
    • Internet service providers
    • advertising identifier of your device
  • Usage Information. We collect information on your use of the Services, such as:
    • time spent on the Services
    • interaction with the Services
    • login information for e.g. retention metrics
    • the time and date of your visits to the Services
    • the sections of the Services you visited

Cookies

We use various technologies to collect and store Analytics Data and other information when you visit the Services, including cookies and web beacons.

Cookies are small text files sent and saved on your device that allows us to identify visitors of the Services and facilitate the use of the Services and to create aggregate information of our visitors. This helps us to improve the Services and better serve you. The cookies will not harm your device or files. We use cookies to tailor the Services and the information we provide in accordance with your individual interests. 

You may choose to set your web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers: 

Safari
Google Chrome
Internet Explorer
Mozilla Firefox

Please note that some parts of the Services may not function properly if use of cookies is refused.

A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read. 

Web analytics services

The Services use certain web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Services.

3. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA

Purposes

There are several purposes for the processing of your personal data by Reforged Studios:

To provide the Services

Reforged Studios processes personal data of the Registered Users to be able to offer the Services to the Registered User under the contract between the Registered User and Reforged Studios.

We also use the data for example to handle the Registered User’s payments or any refunds (where applicable). If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. 

For our legal obligations

We process data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.

For claims handling and legal processes

Reforged Studios may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.

For communication and marketing

Reforged Studios may process your personal data to contact you regarding the Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Services to you. 

For quality improvement and trend analysis

We may also process information about your use of the Services to improve the quality of the Services e.g. by analyzing any trends in the use of the Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.

Legal grounds for processing

We process personal data of the Registered Users to perform our contractual obligations towards the Registered Users and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.

In some parts of the Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.

4. TRANSFER TO COUNTRIES OUTSIDE EUROPE

Reforged Studios stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile. 

We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework

More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above. 

5. RECIPIENTS

We only share your personal data within the organization of Reforged Studios if and as far as reasonably necessary for the purposes of this Privacy Policy.

We do not share your personal data with third parties outside of Reforged Studios’ organization unless one of the following circumstances applies:

For the purposes set out in this Privacy Policy and to authorized service providers

To the extent that third parties need access to your personal data in order for us to perform the Services, Reforged Studios has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations. Such third parties include Apple and Google, acting as our payment service providers, that process certain personal data collected by them as controllers in accordance with their privacy policies.

We may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, IT, sales and marketing services providers) to process it for us and to payment service providers to process Registered Users’ payments to us.

When data is processed by third parties on behalf of Reforged Studios, Reforged Studios has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Services, the processing is typically based on their policies and standards.

For legal reasons and legal processes

We may share your personal data with third parties outside Reforged Studios if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Reforged Studios, you or the public as far as in accordance with the law. When possible, we will inform you about such processing.

For other legitimate reasons

If Reforged Studios is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give you notice when your personal data are transferred or become subject to a different privacy policy if your personal data is concerned. 

With your explicit consent

We may share your personal data with third parties outside Reforged Studios when we have your explicit consent to do so. You have the right to withdraw this consent at all times. 

6. STORAGE PERIOD

Reforged Studios does not store your personal data longer than is legally permitted and necessary for the purposes of this Privacy Policy. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.

Most personal data relating to a Registered User’s user account with the Services will be deleted immediately after the Registered User has deleted his/her user account with the Services. Thereafter, a part of the personal data relating to a Registered User’s user account with the Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a Registered User’s user account with the Services will be deleted within a period of 10 years after the Registered User has deleted its user account with the Services, with the exception of personal data required in certain rare situations such as legal proceedings.

We will anonymize Analytics Data of Users as soon as possible.

7. YOUR RIGHTS

Right to access

You have the right to access and be informed about your personal data processed by us. You may request a copy of your personal data. In addition, we give Registered Users the possibility to view certain data through their user account with the Services.

Right to withdraw consent

In case the processing is based on a consent granted by you, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. 

Right to erasure

You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. 

Right to object

You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the purposes of this Privacy Policy. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Services.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Services. For instance, using the online games provided by us may become impossible if you apply your right to restriction of processing.

Right to data portability

You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.

How to use your rights

The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. 

8. DIRECT MARKETING

You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.

9. LODGING A COMPLAINT

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).

10. INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Services, systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.